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What Government Point of Entry site must our opportunities be posted to?


aordway

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My question relates to the requirement to post notices (synopses, solicitations, etc) to the Government Point of Entry (GPE), but at the same time being required (as an Army employee) to post to the Army Single Face to Industry site (ASFI).

FAR 5.2(b )(1) requires synopses to be posted to the Government Point of Entry (GPE) if they don't meet an exception. FAR 5.102(a)(5) requires solicitations be posted to the GPE if they do not meet one of the listed exceptions. The FAR states in 5.201(d) that the GPE for various postings (synopses, solicitations, etc) can be accessed at http://www.fedbizopps.gov, which means to me that FedBizOpps is the GPE.

However, since we are an Army office, we are required by AFARS 5105.101(a)(1) to post all solicitations to Army Single Face to Industry (ASFI) website. Yet that same paragraph also says "ASFI sends data to the Government point of entry, the Federal Business Opportunities".

It is unclear if we must post opportunities via the ASFI site just so that they will be transfered to FedBizOpps, or if posting to ASFI meets the requirement to post to the GPE, and we should be unconcerned if transferring to FedBizOpps happens. Can notices remain on ASFI and still meet the FAR/AFARS requirements to post to the GPE? Or must we ensure all postings to ASFI go to FedBizOpps? I believe other departments (Air Force, Navy, etc) have similar sites to ASFI.

To sum up, are our opportunity postings required to be on ASFI, FedBizOpps, or both?

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aordway,

I'm not an Army 1102, so take my post with several metric tons of salt, but:

One thing that has always stuck in my mind regarding agency supplements is this: Agency supplements can only be more restrictive, not less restrictive, than the FAR. For example, the AFARS could, theoretically, one day make all simplified acquisitions ($3K to $150K) set aside exclusively for SDVOSBs. However, the AFARS could never eliminate the set aside requirement for simplified acquisitions.

Therefore, I would say that the requirement must be posted to both systems; however, it looks like ASFI is set up to cross-post to FBO without additional intervention by the user. If you want to be sure, check FBO for your solicitation/announcement once you have posted to ASFI.

I would recommend you look at the FAQ document titled "FedBizOpps Posting Guide" found at this link.

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I noticed (no pun intended) that AFARs requires solicitations to be posted to the ASFI but not synopses.

Are you really asking if you are responsible to post the solicitation in two places if the ASFI site doesn't transfer to GPE? It would appear so. The AFARS supplements but doesn't trump the FAR requirement that all solicitations be available at the GPE. The Army site is supposed to feed the GPE.

Is there a problem with the transfer function? Just curious. Otherwise, what is the point of your question?

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To sum up, are our opportunity postings required to be on ASFI, FedBizOpps, or both?

To sum up the response, which you have seen, per FAR and AFARS the answer is "both" for solicitations. Synopses are to be posted to the GPE.

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  • 3 weeks later...

Is there a problem with the transfer function? Just curious. Otherwise, what is the point of your question?

In fact there is. If you post a solicitation to ASFI that never before had a synopsis posted under that same solicitation number, then the solicitation will not transfer to FBO (the exception is a combined synopsis-solicitation which will successfully transfer). ASFI confirmed that this is how the site currently functions. So if I post an under-SAT solicitation on ASFI, for which no synopsis was required pursuant to FAR 5.202(a)(13), then it stays on ASFI.

Once we figured out this issue, our workaround was to post combined synopsis-solicitation formats for all commercial actions (even under SAT) even though the synopsis part of it was not required, since the combined synopsis-solicition will trasnfer from ASFI to FBO, and therefore meet the FAR requirement (for non-commercial actions where the combined synopsis-solicitation format is not allowed, we must first post a synopsis for under-SAT actions so that the subsequent solicitation will successfully transfer).

I just wanted to verify that we indeed needed to have notices on BOTH sites so that we were not wasting effort trying to get all this stuff on FBO and posting unnecessary synopses. Based on Joel's summary, solicitations must be on both sites, and synopses must be on FBO (although we do not have the option of posting directly to FBO, so in effect solicitations and synopsis must both be posted to ASFI and verified that they get to FBO whatever way possible).

Thanks for the help.

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Yet another contracting system where the tail wags the dog. If there is a way to initiate a criteria change request or equivalent, I recommend that you initiate one to advise the systems administrators of the anomaly. Unfortunately, not all sites are flexible enough to recognize errors in their programming.

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