There are three routes commercial cloud service providers (CSPs) can take to be compliant with the government’s baseline cloud computing standards, known as the Federal Risk and Authorization Management Program (FedRAMP). Although these three routes lead to the same ultimate goal, they can differ in time to accreditation and also differ in cost.
Route to FedRAMP #1
The first route, and the most common for commercial cloud service providers, is gaining a provisional authority to operate or (ATO) from the FedRAMP Joint Authorization Board (JAB). This board is led by CIO’s at the General Sales Administration (GSA), the Department of Defense (DOD), and the Department of Homeland Security (DOS). In addition to an ATO, a FedRAMP-accredited third-party assessment organization (3PAO) is required to complete this process.
Route to FedRAMP #2
The second route comes as an alternate. Agencies can grant an ATO to a CSP, and other agencies can choose to take advantage of this authority and work with the company as well. 3PAOs also work with agency-issued ATOs and work with both parties to make sure security standards are met.
Route to FedRAMP #3
The third route and least common is the CSP Supplied route. In this route, a CSP can hire a FedRAMP-accredited 3PAO to complete all required documentation, testing and security assessments. Once all these procedures are complete, the information is sent to GSA’s FedRAMP office for verification. Very few companies have taken this route, due to high cost, but it is a good option for companies that cannot or do not want to take advantage of existing federal contracts and do not wish to partner with other CSP’s.
At the FedRAMP Industry Fair on June 4, 2014 the GSA released a table, which outlined the approximate time it took to become compliant with the government’s baseline cloud computing standards. This table broke out the three routes toward compliancy, under the categories JAB P-ATO’s (Joint Authorization Board) (provisional authority to operate), Agency ATO’s, and CSP Supplied. The timeframe can be found below:
- JAB P-ATO’s: 9+ Months
- Agency ATO’s: 4+ Months
- CSP Supplied: 6 Weeks
As you can see, the process to become cloud computing compliant becomes quicker, when more money and more energy is spent trying to achieve it. These three paths give options, and these options are for companies to choose. This enables you to ask yourself, what route will you take?
Three months after the GSA released a Request for Proposals (RFP) for the latest version of the office supply contract, OS3, they have created a dashboard to share the benefits of strategically sourced office supplies with the public. The dashboard will be used to share details on pricing and sales using colorful images and graphics (view dashboard).
The dashboard also allows users to filter the data by federal agency, small or large business sales, socio-economic status, and geographical sales statistics. The goal of this site is to show the GSA cost savings that the government is achieving through the strategic sourcing initiative.
As a result, during the past four years “the Federal Strategic Sourcing Initiative Second Generation Office Supplies (OS2) BPA has saved more than $364 million” for taxpayers and the federal government. The goal is that federal agencies will continue to reduce administrative and other costs with OS3 and the dashboard is the tool the GSA has created to display these savings. Despite the extensive detail the new dashboard offers, much of the OS3 generation is using the tool as a method for targeting the agencies that have displayed high levels of engagement in the OS3 community.
The GSA SmartPay® program is the largest charge card program in the world today. It was established fourteen years ago to provide the government a more efficient way to conduct business transactions. According to GSA more than 350 Federal agencies, organizations, and Native American tribal governments participate in the GSA SmartPay program. Today, it is reported that there are nearly 3 million cards in circulation.
As a GSA contractor, it is instrumental to understand how the GSA SmartPay® 2 charge card works. According to the General Systems Administration, “you can maximize your ability to capture government sales by accepting these cards.” Other incentives for accepting a GSA SmartPay® 2 charge card include, having fewer forms to fill-out during transactions, as well as having electronic records of sales.
GSA SmartPay® 2 charge cards are easy to identify, because there are only four different card designs, and each have the GSA logo displayed. Another way of spotting a GSA SmartPay® 2 charge card is by its Bank Identification Number (BIN). A BIN is the first four numbers in the sequence of the card, and each of the four different types of GSA SmartPay® 2 charge cards have specific BINs. Since the GSA SmartPay® 2 charge cards are easy to recognize, it allows contractors to track and report federal sales more efficiently.
Contractors who “do not currently accept these cards, can contact any financial institution or one of the GSA SmartPay® three contractors (i.e. Citibank, JPMorgan Chase, and U.S. Bank) to establish a merchant account (GSA SmartPay® 2 vendor brochure)”. There are four different offer types of GSA SmartPay® 2 charge cards that are offered: purchase cards, travel cards, fleet cards, and integrated cards. The GSA SmartPay® 2 charge cards are either VISA, MasterCard, Voyager, or Wright Express. However, Voyager and Wright Express cards are only used for fleet related purchases.
This is another step the GSA is taking to increase collaboration between government and industry. They have launched a new social media community on Interact.gsa.gov for its Governmentwide Acquisition Contracts (GWACs), Alliant II and Alliant Small Business II. This is an excellent step forward as the new community will provide an advanced connection between the GSA and their customers, contractors, and aspiring Alliant customers.
In addition to the providing a strengthened connection, the GSA’s GWAC community will be collecting input and feedback from the community to provide improvements to their future versions of Alliant GWAC initiatives. These are exciting efforts after the success of the OASIS interact community proved that the feedback from the community was very beneficial toward the advancements in the OASIS program. Some interesting facts GSA Schedule holders can note is that the current Alliant GWACS for IT services is extremely successful as federal agencies have conducted more then 20 billion dollars worth of business since 2009. This new social community also encourages President Obama’s Open Government Initiative (OGI) as the transparency additions from the GSA are opening doors between customers and government. These newer additions will also promote more relationships and potential business development with the Alliant users.
Read more about the new social media community for GWAC users in this news release.
The Lead Free compliance Act will take effect nationally 1/4/2014. As GSA contract holders, you must adhere to the new regulations for plumbing related products sold. If you keep these products on your schedule, your company will be responsible for the liability.
The Lead Free Act States
Reduction of Lead in Drinking Water Act – Amends the Safe Drinking Water Act to exempt from prohibitions on the use or sale of lead pipes, solder, and flux: (1) pipes or plumbing fittings or fixtures, including backflow preventives, that are used exclusively for non-potable services such as manufacturing, industrial processing, irrigation, outdoor watering or any other uses where the water is not anticipated to be used for human consumption; or (2) toilets, bidets, urinals, fill valves, flush-o-meter valves, tub fillers, shower valves, service saddles, or water distribution main gate valves that are two inches in diameter or larger.
Re-defines “lead free” under such Act to mean (1) not containing more than 0.2% lead when used with respect to solder and flux (current law); and (2) not more than a weighted average of 0.25% lead when used with respect to the wetted surfaces of pipes and pipe and plumbing fittings and fixtures.
Establishes a formula to calculate the weighted average lead content of a pipe or plumbing fitting or fixture.
GSA contractors that offer these plumbing related products and services should take note of the new compliance measures in the act and consider consulting with professionals to make they are remaining fully compliant with the new Lead Free Act.
65% of GSA Schedule contract holders reported under $150,000 in sales for FY2013. When we zoom in on that figure, we noticed a distinct difference in not understanding capture management as a concept, but rather documenting and implementing a management process is the BIG difference maker. Simply stated, qualifying new business opportunities at the beginning of the procurement life cycle will increase your companies win rate. There are ten crucial steps every GSA contract holder should take when successfully building a capture management plan. These steps are:
- Analyze and qualify *NEW* opportunities
- Develop, define, and document your capture management plan
- Understand the issue(s) and the agency(s)
- Map your solution to the agency issue(s)
- Demo Solution & Influence the Opportunity
- Competitor Analysis
- Reassess the opportunity
- Price-to-win strategy
- Partner & teaming tactics
- Assess the contract’s risk
The first step is developing, defining, and documenting an internal process, which can be overlaid with your current operations. It should be noted that developing, defining, and documenting your capture management plan alone will not increase your win rate. In order to achieve a higher win rate, the capture management plan needs to be supported by all stakeholders in the process – ranging from the sales and marketing team to the executive management team. Using these ten steps and actively engaging in your capture management plan can be a strong indication of how successful a government contractor will be in the marketplace. To reiterate, government contractors need not only to implement a capture management plan, but also actively perform the activities in the plan in order to achieve success.
According to a top agency official at the General Services Administration (GSA), the agency is exploring the idea of adding a cost-reimbursable option to its Multiple Award Schedules (MAS). While the GSA hasn’t released a definite date for when this option will become available, they have stated that the cost-reimbursable option will be available soon. In a statement made to the Federal Times, the commissioner of the GSA’s Federal Acquisition Service, Tom Sharpe, said the assessment “will include thinking through and working on a wide array of issues, and will not be a short-term action.” The GSA’s One Acquisition Solution for Integrated Services (OASIS) contract vehicle will include the cost-reimbursable option that will become available to government agencies. This new endeavor is the result of the Pentagon pushing the GSA to create a cost-reimbursable schedule that will create more value for government agencies.
Cost-reimbursement contracts are based on payments of allowable incurred costs, provide for payments of allowable incurred costs, to the extent prescribed in the contract. These contracts establish an estimate of total cost for the purpose of obligating funds and establishing a ceiling that the contractor may not exceed without the approval of the contracting officer. Cost reimbursable contracts are suitable when the uncertainties involved in contract performance do not allow costs to be estimated with sufficient accuracy to use any type of fixed price contract. As of now, the only way for government agencies to benefit from the contract schedules is by using fixed-price or time and materials contracts. To combat this inflexible option for Federal government agencies, the GSA’s Federal Acquisition Service will be developing this next generation contract vehicle for complex professional services.
The GSA will be engaging Federal agencies and industries in a collaborative process to identify the most advantageous structure and the best practices to incorporate into the design of their OASIS contract vehicle. These measures will be taken to reach the ultimate goal of creating a contract vehicle that provides the total solution for agencies’ requirements while maximizing opportunities for small business contractors. Businesses must be registered in the System for Award Management (SAM) to bid on this new contract. As this registration may be difficult and time consuming, companies wishing to take advantage of this opportunity should contact the proper GSA Schedule consultants for the value of their extensive government contracting knowledge and experience.
For contractors offering products and/or services to the government through the General Services Administration’s (GSA) and Veteran’s Affairs (VA) Multiple Award Schedule program, keeping up with Industrial Funding Fee (IFF) payments is a critical component of GSA contract compliance and contract maintenance. Government agencies prefer to procure through the MAS program and incur the IFF because of the resulting benefits, particularly compared to the cost of the customer staff time needed to award a new procurement. By selling through GSA’s Multiple Award Schedule and paying the IFF, GSA & VA contractors will have easier payment options, hassle-free volume purchase prices, flexible purchasing options, and no order limitations among additional benefits.
The Industrial Funding Fee is a fee to cover GSA’s cost of operating the Federal Supply Schedules (FSS) program. This fee is a fixed percentage of reported sales under GSA &VA Schedule contracts that is paid quarterly by contractors. The IFF on Schedule 599 for Special Item Number (SIN) 599-2 is $1.50 per transaction. The IFF for all other SINs and Schedules is 0.75% of sales. The IFF is included in the price that government agencies pay the contractor when they purchase items from a MAS contract. Quarterly IFF reporting and payments are due by the 30th day of January, April, July, and October. Contractors must still report sales for each quarter even if no sales occur by entering “zero” (0) in the sales report. To avoid overpayment, it is important that the contractors only report sales for products or services on their Awarded GSA Pricelist to avoid overpayment of the IFF and ensure accuracy. Contractors can only send the IFF payment after sales have been reported. Once sales are reported, the IFF payment can be made by check, electronic funds transfer, or credit card. For more information on how to make an IFF payment online in the 72A Quarterly Reporting System, visit the instructions page.
As the first quarter of Fiscal Year 2014 (FY2014) is wrapping up and the year’s first Industrial Funding Fee payment is due January 30th, MAS contractors should be preparing to report their first quarter sales and make the necessary IFF payment to remain in compliance with their contract. Making quarterly IFF payments is only one factor in GSA contract compliance. To learn more about IFF compliance, you may want to consult with MAS contracting professionals and verify that your firm is not overpaying or underpaying this required fee.
GSA contractors can mail their IFF Payments to the mailing address listed below,
Industrial Funding Fee Mailing Address
General Services Administration
ACCOUNTS RECEIVABLE BRANCH (6BCDR)
P.O. Box 979017
St. Louis, MO 63197-9017
The government shutdown which occurred on October 1, 2013 has left many businesses wondering how to approach the upcoming Fiscal Year 2014. Many government contracts were placed on halt during the shutdown and numerous were also terminated. The economy and many commercial businesses have suffered, and as a result they are looking for a solution to create a more prosperous year.
Before a commercial company wins a government contract, there is much research and preparation to be done first. The research and planning phase begins with careful consideration and recognizing the strengths in your product and/or service. Many businesses aren’t aware that the resources for doing business with the government are readily available online. Websites such as USAGov and U.S. Government Blue Pages can be very instrumental in your research. Another important consideration is recognizing what category your business falls into, which reflects back to your strengths. Knowing where your business falls in the small or large business spectrum can effectively help you identify which government departments to market towards and contact for possible contracting engagements.
Many commercial businesses still fail to understand how to expand their business within government agencies. Here are 5 tips for growing your business with the government:
- Develop a Government Sales & Marketing Plan – Review the Agency’s Mission, procurement forecast and budget, this will allow you to target the right agencies.
- Find Who the Decision Makers Are and Talk with Them – Talking to the right person can make a world of difference in the time it takes to close a deal.
- Analyze How You Currently Market to the Government – Market to the government just like a commercial client by raising your federal brand awareness.
- Find Your Government Competition – Knowing your competition can help you understand the market and where to go after opportunities.
- Find Teaming Partners – Government agencies encourage teaming and partnering among companies competing for government contracts. This partnership builds past performance while building a relationship with the government agency.
Following these 5 tips will help to ensure your company’s success in government contracting and increase your revenue over the next fiscal year.
To learn more on this topic, we encourage business leaders and GSA Schedule contractors to watch this webinar, “Growing your Government Business during the FY2014 Crisis.”
You can also watch this and other government contracting webinars on Winvale’s YouTube channel.