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The Great Migration: GSA Sales Reporting and IFF Transition – 72A to FAS SRP

By Julia Coon, Clause 552.238-74 Industrial Funding Fee and Sales Reporting requires all General Services Administration (GSA) Schedule contractors to report sales within 30 calendar days following the completion of the reporting period and remit the Industrial Funding Fee (IFF) within 30 calendar days following the end of each reporting quarter. Over the next twelve months, GSA will be transitioning all GSA Schedule contracts from the legacy 72A Reporting System to the new Federal Acquisition

Centre Law & Consulting

Centre Law & Consulting

The Ghosts of Performances Past (Or Lack Of)

By Stephanie Fine, Esq. With the holidays upon us and the new year just around the corner, it is time to start thinking about new solicitations in the pipeline for the next calendar year and your record of past performance. Almost every government proposal requires information on past performance, and it’s inarguably one of the most critical parts. Why does past performance matter? Past performance shows the government that your company is capable of performing the work it says it can. It’

Centre Law & Consulting

Centre Law & Consulting

The Ghosts of Performances Past (Or Lack Of)

By Stephanie Fine, Esq. With the holidays upon us and the new year just around the corner, it is time to start thinking about new solicitations in the pipeline for the next calendar year and your record of past performance. Almost every government proposal requires information on past performance, and it’s inarguably one of the most critical parts. Why does past performance matter? Past performance shows the government that your company is capable of performing the work it says it can. It’

Centre Law & Consulting

Centre Law & Consulting

The Ghosts of Performances Past (Or Lack Of)

By Stephanie Fine, Esq. With the holidays upon us and the new year just around the corner, it is time to start thinking about new solicitations in the pipeline for the next calendar year and your record of past performance. Almost every government proposal requires information on past performance, and it’s inarguably one of the most critical parts. Why does past performance matter? Past performance shows the government that your company is capable of performing the work it says it can. It’

Centre Law & Consulting

Centre Law & Consulting

The GAO Weighs in on SBA’s New Five Year Annual Receipts Average

By Heather Mims, Esq. Contractors (and officials) across the country have experienced some confusion about the implementation of the recently enacted Small Business Runway Extension Act of 2018. If you’re unfamiliar with the Act, Congress has amended the Small Business Act to modify the method for prescribing size standards for business concerns – what used to be a three-year standard has now become a five-year standard. Thus, the implementation of this Act would extend the measurement period o

Centre Law & Consulting

Centre Law & Consulting

The FAR Now Available in the Kindle Bookstore

Just in time for the consummate workaholic acquisition professional to read while lying on the beach this summer, and for those who never want to get too far away from the Federal Acquisition Regulation (FAR), the General Services Administration (GSA) Office of Government-wide Policy, in conjunction with the FAR Council announced June 20, 2017, the release of the FAR in the Kindle Bookstore. The FAR is now available in eBook format for free in the Amazon Kindle bookstore.  Users can highlight t

The Exit of SIP and Entrance of the Formatted Product Tool

If you have been working on GSA Schedules for the past few years, you may remember that in May 2012, GSA’s initiative was the end of the Schedule Input Program (SIP) and the mandatory use of the new Formatted Price List (FPL) for the Financial and Business Solutions (FABS) Schedule. There was much excitement generated by this news as we were all ready for the end of SIP. In January 2014, GSA announced that FABS would no longer utilize the FPL and all vendors were to return to SIP. As we look int

The Earth is Flat but Not My Driveway

By Barbara Kinosky My Driveway I wake up to yet another day of rain in the Washington D.C. metro area.  It wouldn’t be so bad if my driveway was not a mud pit.  Years ago a crafty driveway company talked us into a pebble driveway which looked like it was in Architectural Digest – for all of a couple of years.  Rocks eventually roll downhill and my driveway has a definite slope to it.  I also have discovered that it is cheaper to put down gravel than it is to remove it and that crews don’t like

The DOD Cybersecurity Maturity Model Certification: Is Your Organization Prepared?

By Angel N. Davis, With Cybersecurity awareness a keen focal point, regardless of business size, Government Contractors now have an overwhelming responsibility to ensure the safeguarding of sensitive customer data. The latest Department of Defense (DOD) regulation being developed to support the growing number of cybersecurity concerns , is the DOD Cybersecurity Maturity Model Certification. The DOD issued a new draft of the CMMC Model, version, 0.6 on November 7, 2019. According to DOD, the CM

Centre Law & Consulting

Centre Law & Consulting

The Annual List of Labor Surplus Areas are Available

The Department of Labor has published its annual list of Labor Surplus Areas (LSA) for Fiscal Year 2018.  What is a LSA you ask?   A LSA is a civil jurisdiction that has a civilian average annual unemployment rate during the previous two calendar years 20 percent above the average annual civilian unemployment rates for all states & Puerto Rico during the same period.  Civil jurisdictions are defined as follows: A city of at least 25,000 population on the basis of the most recently availabl

The 116th Congress More Congressional Review Act Action?

By Wayne Simpson, CFCM, CSCM In 2017 when the new administration entered office, and with both houses of Congress controlled by the same party in the 115th Congress, the Congressional Review Act of 1996 was used dozens of times in the first session of the 115th Congress to rescind Executive Orders, regulations, rules and policies issued by the previous administration.  As of June 2018, 17 public laws were enacted using this authority. Fast forward to the 116th Congress convening at Noon Easter

Centre Law & Consulting

Centre Law & Consulting

The 116th Congress More Congressional Review Act Action?

By Wayne Simpson, CFCM, CSCM In 2017 when the new administration entered office, and with both houses of Congress controlled by the same party in the 115th Congress, the Congressional Review Act of 1996 was used dozens of times in the first session of the 115th Congress to rescind Executive Orders, regulations, rules and policies issued by the previous administration.  As of June 2018, 17 public laws were enacted using this authority. Fast forward to the 116th Congress convening at Noon Easter

Centre Law & Consulting

Centre Law & Consulting

The 116th Congress More Congressional Review Act Action?

By Wayne Simpson, CFCM, CSCM In 2017 when the new administration entered office, and with both houses of Congress controlled by the same party in the 115th Congress, the Congressional Review Act of 1996 was used dozens of times in the first session of the 115th Congress to rescind Executive Orders, regulations, rules and policies issued by the previous administration.  As of June 2018, 17 public laws were enacted using this authority. Fast forward to the 116th Congress convening at Noon Easter

Centre Law & Consulting

Centre Law & Consulting

The “Veterans Affairs Purchase Card Misuse Mitigation Act”

By Wayne Simpson, CFCM, CSCM House Moves to Prevent Abuse and Misuse of SmartPay Program’s Largest User On May 21, 2018, after 40 minutes of floor debate, the U.S. House of Representatives considered under the suspension of the rules, and passed H.R. 5215, the “Veterans Affairs Purchase Card Misuse Mitigation Act” by voice vote.  The bill was sent to the Senate May 22, 2018, for consideration. H.R. 5215 amends Title 38 of the United States Code to direct the Secretary of Veterans Affairs to p

System for Award Management (SAM) Roll Out to Consolidate Ten Affiliated Sites

The System for Award Management (SAM) is a system in which contractors must register in order to do business with the federal government. SAM was created to consolidate and eliminate some of the legacy systems. SAM’s goal is to consolidate a majority of the federal procurement systems into one user friendly system. The next phase for SAM modernization is due to be released in September 2017. The new beta.SAM.gov being released is the Office of the Integrated Award Environment’s (IAE) effort to c

Supreme Court Reduces Information Available Under FOIA

By Barbara S. Kinosky, Esq. Hot News! Supreme Court Ruling from June 24, 2019 The Supreme Court just gave a victory lap to Freedom of Information Act (FOIA) submitters and a defeat to those requesting information under the Act.  In Food Marketing Institute v. Argus Leader Media, the Court held that: Where commercial or financial information is both customarily and actually treated as private by its owner and provided to the government under an assurance of privacy, the information is “confide

Supreme Court Nominee Brett Kavanaugh and the Coming Political “Kabuki Theater”

By David Warner, I have been fascinated with the political theater around U.S. Supreme Court nominees ever since the contentious Clarence Thomas confirmation hearings gave rise to one of the greatest Saturday Night Live cold openings of all time. (Viewer beware, 2018 “sensitivities” might conflict with 1991 standards of humor. It’s still a classic.) Given our current President and the fact that the incoming justice will replace the “swing vote” of retiring Justice Anthony Kennedy, it is widely

Subcontracting Payment Rules: Make the Payment or Incur the Penalty

The Payment of Subcontractors proposed rule, which appeared in the Federal Register in January 2016, is the latest in a series of efforts to hold the Prime accountable for timely payments to its Subs. Those who follow these blogs know that ‘payment’ is a hot button topic for me whether it is payment to the Prime by the Government or payment to the Subcontractor by the Prime. We’ve previously highlighted the “Accelerating Payments to Small Businesses” rule whose aim is to enable small business

Staying Vigilant – Why the Task of Ethical Compliance Under the FAR is Never Complete

By Edward W. Bailey,   All too often, federal contractors let their guard down when it comes to their ethical duties under the Federal Acquisition Regulations (FAR). This is largely because the FAR’s provisions concerning ethical conduct do not provide much specific guidance. For example, FAR § 52.203-13 requires contractors to have a “written code of ethics”, exercise “due diligence to prevent and detect criminal conduct”, and otherwise “promote and encourage” ethical conduct and compliance

Centre Law & Consulting

Centre Law & Consulting

Square Pegs and Round Holes – OSHA Reporting Requirements A Difficult Fit for COVID-19

By Tyler Freiberger, Esq., As pandemic restrictions are beginning to ease, employers are increasingly challenged with knowing and meeting their obligations concerning COVID-19 prevention in the workplace. The confusion and shifting nature of these goal posts is best exemplified by the Department of Labor’s recent revised memorandum advising that employers are responsible for recording cases of COVID-19 occurring in the workplace. On first read, the new requirements can seem overwhelming, and th

Spring Cleaning: It’s Time to Spruce Up Your Multiple Award Schedule

By Julia Coon, As you are completing your annual spring cleaning, do not forget to spruce up your Multiple Award Schedule (MAS) contract. It is important to regularly review and update your MAS contract to ensure your company is in compliance with your contract requirements. Some of the key areas to review when sprucing up your MAS contract are highlighted below. Digital Certificates & Authorized Negotiators: All contractors should ensure their digital certificates are active and the inf

Spring Cleaning for Your GSA Schedule

As spring approaches, it’s the time of year when we are all busy dusting off and cleaning up around the house, but do not forget to spruce up your General Services Administration (GSA) Schedule contract as well. Below are key items to consider when spring cleaning your GSA Schedule: Authorized Negotiators/Digital Certificates: Have you reviewed the authorized negotiators on your GSA Schedule recently? If any authorized negotiators need to be removed or added, this can be completed via an admin

Small Business and Working With Similarly Situated Entities

If you are like me and work for a small business, you have been patiently waiting for the FAR Council to implement the Small Business Administration’s final rule from June 2016 that made major changes to the way performance requirements apply to small business in set-aide contracts. For those who don’t know, this change allows for a prime small business, WOSB, SDVOSB, EDWOSB, 8A, or a HUBZone company to subcontract in service contracts to similarly situated firms and not count towards the 50% s

SIP – As Easy As 1-2-3

By Julia Coon GSA Advantage!® is the General Services Administration (GSA)’s online shopping and ordering system that provides access to products and services offered under the GSA Schedule program. Once a new schedule contract or modification is awarded, contractors have 30 days from the effective date to upload their pricelist to GSA Advantage!®  The pricelist can be uploaded to GSA Advantage!® through the Schedules Input Program (SIP). GSA’s SIP software is free to Schedule contractors and

Centre Law & Consulting

Centre Law & Consulting

Single Multiple Award Schedule (MAS) Modification Guidance Package Released and COVID-19 Update

By JW Butler Multiple Award Schedule Modification Guidance On March 6, 2020, GSA released the final MAS Modification Guidance package. The new MAS Modification Guidance package can be found here. GSA previously had different modification guidelines for the 24 different legacy Schedules, but with the release of this modification package all contractors under the new MAS will follow the same guidelines for modifications. There are still specific instructions for each type of modification, but r
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