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Tags Archives: SAT

IT-70 Prepares For a New Addition With the Creation of a Cyber Security SIN

Source: Winvale – GSA Schedule Blog

10 Important Facts About the New Health IT SIN

Source: Winvale – GSA Schedule Blog

Everything You Need to Know About the HCaTS Contract Vehicle

Source: Winvale – GSA Schedule Blog

New Amendment to Federal Acquisition Regulation (FAR)

FARA new amendment to the Federal Acquisition Regulation (FAR) will greatly impact the way service providers track both theirs and subcontractor hours. The ruling comes from the Federal Activities Inventory Reform (FAIR) act that mandates agencies annually submit an inventory of activities performed by service contractors to the Office of Management and Budget (OMB). The new rule requires that prime contracts submit their hours worked.

This new amendment requires contractors with fixed-priced definite-delivery contracts to track and report hours worked on their service contracts. Prime contractors will not only be responsible for their own internal hours, but for reporting the hours worked by their first-tier subcontractors as well. First –tier subcontracts are those awarded directly by the prime contractor for the purpose of acquiring supplies or services (including construction) for performance of a prime contract. This does not include the supplier agreements with vendors, such as long-term arrangements for materials or supplies that benefit multiple contracts and/or the costs of which are normally applied to a Contractor’s general and administrative expenses or indirect costs.

The new rule will be implemented in the following phases with regards to fixed-priced definite-delivery contract values:

  • $2.5 million in Fiscal Year 2014.
  • $1 million in Fiscal Year 2015.
  • $500,000 from Fiscal Year 2016 onwards.

While cost-reimbursement, time-and-materials, and labor-hour contracts already track and report hours, the determining dollar threshold has been lowered to the simplified acquisition threshold (SAT), which is currently $150,000

In regards to IDIQs, FSS contracts, GWACs, and multi-agency contracts, the reporting requirements will be determined based on the expected dollar amount and type of orders issued under the contracts. For any existing indefinite-delivery will be modified bilaterally within six months of January 30, 2014 so long as the contract performance period extend past October 1, 2013; and there is $2.5 million or more obligated.

This rule change applies to both solicitations and contracts issued on or after January 30, 2014. The DoD is exempt from this requirement as the DFAR already stipulates this reporting requirement. Reports will be due annually by October 31, for services performed during the preceding Government fiscal year (October 1-September 30).

The new amendment can be found under FAR clauses 52-204-14 and 52-204-15.

What is Best Value Pricing?

Best value pricingThe General Services Administration’s (GSA) goal with all GSA Schedule contracts is to ensure the best value pricing possible for government buyers. When negotiating contracts, the GSA requires that companies offer pricing comparable or better than what is given to their most favored non-government customers. This is a major reason why GSA Schedule contracts are such a popular vehicle for government procurement.

The requirement of best value pricing for GSA Schedule contracts should not hurt vendors because they only need to supply the best pricing that they already offer to other customers. In addition, generally orders received from government agencies are much higher in value compared to those from non-government customers, so offering deeper discounting incentivizes contractors to win larger government opportunities. Government agencies are encouraged to seek further price reductions before placing an order through GSA Schedule contracts. Agencies are required to seek further price reductions when placing orders over the Simplified Acquisition Threshold (SAT) or when establishing Blanket Purchase Agreements (BPAs). Contractors are not required to offer further reductions from their stated GSA Schedule prices, but may often do so to increase their chances of winning a bid.

It is imperative that companies cooperate with GSA in offering their best prices for GSA Schedule contracts. Contractors may always offer lower than their GSA prices, but they cannot offer higher. They must always give a greater discount than their Most Favored Customer (MFC) as determined by GSA. If GSA has reason to believe that a contractor is not offering the best price, they may audit the company which can have serious legal and financial ramifications. Companies should work with professional GSA Schedule consultants to make sure they are complying with all the proper GSA requirements and regulations to avoid being audited

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