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Koprince Law LLC

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  1. Koprince Law LLC
    This week we had some actual fall temperatures at the SmallGovCon home offices. It’s finally pumpkin spice weather! We’ll be enjoying the fall weather and some football this weekend. Hope you enjoy the fall weather as well, along with some of top federal contracting headlines, including the continuing resolution to fund the government, new cyber rules, and the opening of the 8(a) portal. 
    Fight over DHS consulting contracts moves to court What’s in the continuing resolution, and when does it expire? New cyber rules aim to standardize requirements for federal contractors SBA Administrator Guzman Releases Statement on the Reopening of the 8(a) Application Portal Sign On Letter to Congress for Stronger Whistleblower Protections for Government Contractors San Antonio Business Owner and Associates Arrested for Defrauding SBA Program Accredited Lenders Program Express Pilot Program Four Indicted For Defrauding Federal Program Intended For Service-Disabled Veteran-Owned Small Businesses In Connection With A Construction Contract For Cancer Treatment Center At Bay Pines VA Medical Center Less than a week in, contractors sort out the meaning of the 45-day continuing resolution Agencies Push for Federal Acquisition Regulation Amendment to Include New SBA Contract Protest Rules Treasury plots departmentwide contract to streamline cybersecurity services Senators move to financially protect contractors during government shutdowns Deputy Interior Secretary Beaudreau to step down The post SmallGovCon Week in Review: October 2-6, 2023 first appeared on SmallGovCon - Government Contracts Law Blog.View the full article
  2. Koprince Law LLC
    Happy Spring, Readers! I don’t know about you but I’m looking forward to warmer temperatures and a lot more sunshine in the coming months. We have had a lot of grey, gloomy weather here in Kansas lately and I feel that we are all ready for some fun, outside activities. Spring is a great time of transition and speaking of transition, I will now transition to some federal government contracting news this week. Have a great weekend and we hope you can enjoy spring in your neck of the woods.
    CIO-SP4 protests dismissed as NITAAC commits to further corrective action [FedScoop] This week in Congress: SecDef defends the White House budget [FedTimes] Federal Contracting Boasts Job Security and High Earnings for Skilled Professionals [EIN] US Department of Labor Will Open Online Portal For Federal Contractors, Subcontractors to Certify Affirmative Action Program Compliance [DoL] Commerce’s CATTS procurement exemplifies all that’s wrong with federal small business contracting [FedNewsNet] For contractors, the 2024 budget request doesn’t quite add up [FedNewsNet] GOP lawmakers want additional details on CMS subcontractor breach timeline [FedScoop] US Department of Labor Recovers $46K in Back Wages for Indiana Construction Workers on Federal Projects [DoL] House Dems introduce pair of bills to overhaul IT acquisition at Department of Veterans Affairs [FedScoop] DOD partners with GSA to get sustainable products to agencies [FCW] Another Appeals Court Rules against Challenge to Coronavirus Vaccine Mandate [FedWeek] The post SmallGovCon Week in Review: March 20-24, 2023 first appeared on SmallGovCon - Government Contracts Law Blog.View the full article
  3. Koprince Law LLC
    Please join Jackie Lopez, President of Premier Enterprise Solutions, LLC, and me as we discuss both the operational and legal perspective of teaming strategies, the importance of teaming, limitations of subcontracting, why you should use a teaming agreement and much more in part 1 of this 2 part webinar series. We’re pleased to offer both
    Event information and registration can be found at this link. I hope you will join us!
    The post U.S. Department of Veteran’s Affairs Webinar Event: Tuesday, October 25 1:00pm EDT first appeared on SmallGovCon - Government Contracts Law Blog.View the full article
  4. Koprince Law LLC
    Solicitations for brand name or equal products are commonly used by contracting officers to ensure that the products procured via the contract meet minimum requirements. However, as one agency found, the salient characteristics required to meet the minimum requirements must be explicitly stated in the solicitation. And, evaluating the product on any characteristics that are not included in the solicitation, even if incorporated by reference to the name brand item, can lead to an improper exclusion of offerors from competition.
    In American Material Handling, Inc., the International Boundary and Water Commission excluded the protester, American Material Handling, from award because the product offered by the protester, a Volvo tractor, did not contain salient characteristics that the name brand product, a Caterpillar tractor, had. So, what was the problem? Why was the protest sustained by GAO but not the agency if the Volvo tractor did not contain the salient characteristics of Caterpillar tractor? Well, the answer to that lies in the solicitation.
    The RFQ was for the award of a contract to the offeror that offered the “lowest-price technically acceptable quotation considering price and technical acceptability.” The RFQ included language stating that the tractor “must meet the salient features or specifications of the Caterpillar 980 or exceed the specifications attached.” The specifications were listed in a two-page specification sheet. As the agency argued, the salient characteristics were specified in the solicitation, so what exactly was the problem here?
    It turns out that while the RFQ did contain the two pages of specifications, the six salient characteristics that the protester was excluded from competition on account of, were not included. Rather, GAO found that the contracting officer added salient characteristics after the quotations. The agency claimed that the reference to the Caterpillar 980 meant that any tractor offered must meet or exceed all characteristics of that brand name product, not just those listed in the specifications contained in the RFQ.
    However, as GAO held, a brand name or equal product does not have to meet every specification of the brand name product to be deemed acceptable when those characteristics are not stated in the solicitation. Therefore, the agency improperly determined that the protester’s Volvo tractor was unacceptable because it actually met all of the salient characteristics that were listed in the RFQ.
    As FAR 11.104(b) requires, solicitations must include “a general description of those salient physical, functional, or performance characteristics of the brand name item that an ‘equal’ item must meet to be acceptable for award.” By evaluating proposals on characteristics not listed in the solicitation, the agency did not evaluate the offers solely on the terms in the solicitation. Which, as any federal contracting attorney would know, is prime real estate for a protest to be sustained.
    Questions about this post? Email us Need legal assistance, call 785-200-8919.
    Looking for the latest government contracting legal news? Sign up here for our free monthly newsletter, and follow us on LinkedIn, Twitter and Facebook.
    The post GAO: Brand Name or Equal RFQ Must Explicitly State All Salient Characteristics first appeared on SmallGovCon - Government Contracts Law Blog.View the full article
  5. Koprince Law LLC
    SmallGovCon has covered the SBA’s assumption of control over certification of Service-Disabled Veteran Owned Small Businesses (“SDVOSB”) and Veteran Owned Small Businesses (“VOSB”) since it was first announced well over a year ago. Now, we are coming close to one of the final deadlines associated with SBA taking over these certification processes. It is hard to believe that it is already the end of the calendar year once again. But time flies when you are having federal contracting fun! With the end of 2023 comes a crucial deadline for certain veteran businesses to keep in mind–the date for self-certification to go away.
    As we discussed during the SBA’s SDVOSB certification rules rollout, self-certification of SDVOSBs was an item that SBA planned to get rid of. In the final rules and in follow up guidance, SBA stated that self-certified SDVOSB contractors would be given a one-year grace period to submit their certification application to the SBA. During that period, SDVOSBs could still self-certify as an SDVOSB. However, after that one-year grace period, SDVOSB self-certification would be eliminated. (That being said, SBA did indicate in its final rule that SDVOSB self-certification would be allowed for subcontracting purposes and goaling credit, for another five more years).
    As you likely know, SBA assumed control of SDVOSB certification on January 1, 2023. So, that one year grace period is coming to an end very soon. As SBA states on its site, there is “one-year grace period for self-certified SDVOSBs until January 1, 2024.” Meaning the grace period’s last day is December 31, 2023, only a few short weeks away.
    SDVOSB contractors who are self-certified were given the one-year grace period to file an application for SDVOSB certification. Consequently, a self-certified SDVOSB that sends in its application for SDVOSB certification to SBA prior to January 1, 2024, “will maintain their eligibility through the expiration of the grace period until SBA issues a final eligibility decision.” Meaning, a SDVOSB could self-certify through 2023 to compete for most SDVOSB set-asides (note, though, that VA does not recognized SDVOSB self-certification), but that ability will end on December 31, 2023. Therefore, if you are a self-certified SDVOSB, you have only a few weeks (as of the date of this blog) to get your application in to the SBA. Applications must be sent to the SBA through the SBA’s VetCert portal. If a self-certified SDVOSB contractor misses that deadline, it will find itself no longer SDVOSB certified and standing in line with other new applicants to regain SDVOSB status. In fact the SBA states “Self-certified SDVOSBs are encouraged to submit an application in advance to ensure the certification process is complete by January 1, 2024.”
    While every application is different, SBA will generally look for the same things. We highlighted many of these in our back to basics post on SDVOSBs and VOSBs. But it basically boils down to two major things: 1) ownership; and 2) control. In general, the SBA will want to make sure service-disabled veteran(s) directly and unconditionally own the majority of the business. The SBA will also want to make sure service-disabled veteran(s) control the business. Control is typically shown through control of the day-to-day affairs and long-term strategic decision-making of the applicant business. Self-certified SDVSOBs applying to SBA will need to keep these things in mind when preparing their applications. The SBA has provided a FAQ, email (vetcert@sba.gov), and toll free line (M-F, 8am-6pm ET, 800-862-8088), for any assistance they can provide. Of course, if you find yourself in the situation of needing to apply for SDVOSB certification, it may be a good idea to reach out to a federal contracting lawyer for input, to see if you meet the certification requirement, because there are many nuances to the eligibility requirements SBA places on contractors for the SDVOSB program.
    Questions about this blog? Email us at info@koprince.com. Need legal assistance?  Give us a call at 785-200-8919.
    Looking for the latest government contracting legal news? Sign up for our free monthly newsletter, and follow us on LinkedIn, Twitter and Facebook.
    The post Reminder: 2023 SDVOSB Deadline Looming first appeared on SmallGovCon - Government Contracts Law Blog.View the full article
  6. Koprince Law LLC
    Updates to the SBA’s Small Business Subcontracting Plan regulations in response to the National Defense Authorization Act of 2020 Section 870 are changing the circumstances in which a prime contractor can receive credit for lower-tier subcontractors, effective November 13, 2023. Such changes make the inclusion of lower-tier subcontractors in certain situations optional and put the onus on the lower tier subcontractors to report such work to the SBA if the lower tier subcontractor wishes to receive credit. It is important to note that these changes have no effect on any first tier subcontracting requirements.
    For those that may be unfamiliar, small business subcontracting plans are a requirement for federal contracts that exceed $750,000, or $1.5 million for construction contracts. A small business subcontracting plan is not needed when an award is made to a small business, there are no subcontracting opportunities, or performance will occur completely outside of the United States and its outlying areas.
    But what is a small business subcontracting plan and why is it important? Well, as implemented by FAR 52.219-9 and 13 C.F.R. § 125.3, small business subcontracting plans describe how an other-than-small prime contractor will meet the small business subcontracting requirements of most federal contracts. And they are important to “provide the maximum practicable subcontracting opportunities for small business concerns.”
    Prior to the most recent change, prime contractors with individual subcontracting plans were required to include information on lower-tier subcontractors. Now, prime contractors have a choice. They can elect to have their lower-tier subcontracting plans considered with their proposal in certain circumstances. This applies only in situations when the subcontracting plan applies to a single contract with one federal agency. For other situations—including commercial plans, comprehensive contracting plans, governmentwide contracts, and multi-agency contracts—contractors are prohibited from receiving credit for lower-tier subcontractors.
    The rule also removes the requirement that a prime offeror submit two different sets of subcontracting goals: one for first-tier subcontractors and one for lower-tier subcontractors. However, the NDAA prohibits agencies from setting subcontracting goals at a specific tier. Therefore, SBA has updated the regulation so prime contractors are only required to submit one small business subcontracting plan regardless of the tier in which subcontractors fall. Note that if the prime contractor wants to receive credit for a lower tier subcontractor, it must incorporate the lower tier subcontractor’s own individual subcontracting plan goals.
    Finally, prime contractors are now required to submit, along with offers, a statement of the types of records the will maintain to substantiate subcontracting credit. However, the prime contractors are not required to make reports for their lower-tier subcontracts. Rather, the lower-tier subcontractors must submit that information on their own.
    Within the comments and responses, commenters hit on a couple of interesting points that come out of this rulemaking. One commenter requested that SBA define its role in holding subcontractors who fail to meet their lower-tier subcontracting goals accountable. In response, SBA said that, aside from the government sending “a ‘show cause’ letter that proposes debarment for subcontractors that repeatedly fail to meet their lower tier subcontracting goals,” prime contractors can accomplish their goals “by not subcontracting to firms that fail to meet subcontracting requirements.” With this, it seems as though SBA will be hands-off unless and until a contractor has failed to meet their subcontracting requirements repeatedly.
    Another commenter requested extra time before the lower tier subcontracting plan was required to be incorporated into the subcontracting plans submitted with proposals, but SBA declined to do so, stating that the plans must be in place by the time of award when required per 13 C.F.R. 125.3(a).
    In a response to another question, SBA recognized that contractors may not know of lower tier subcontracting opportunities when initially awarded a contract, but that any change to the subcontracting plan in place at the time of award must be submitted to the contracting officer for a contract modification.
    And there you have it. Prime contractors may, but are no longer required, to provide lower tier subcontracting information to agencies or the SBA. If desired, the lower tier subcontracts for single contracts with one federal agency will now be included in the prime contractor’s individual subcontracting-plan goals. Finally, if a lower tier subcontractor wants to receive credit for its work on the lower tier subcontract, the lower tier subcontractor must have its own individual subcontracting plan.
    Questions about this blog? Email us at info@koprince.com. Need legal assistance?  Give us a call at 785-200-8919.
    Looking for the latest government contracting legal news? Sign up for our free monthly newsletter, and follow us on LinkedIn, Twitter and Facebook.
    The post FAR Subcontracting Plan Update: Credit for Lower Tier Subcontractors Means Lower Tier No Longer Lower Value first appeared on SmallGovCon - Government Contracts Law Blog.View the full article
  7. Koprince Law LLC
    In this webinar, Govology Legal Analyst Steven Koprince and I will cover the most important legal developments for federal contractors in 2022, including new small business rules, recent domestic preference changes under the Buy American Act, key provisions of the 2023 National Defense Authorization Act, and much more. I hope you will join us. Registration Link is here.
    The post Govology Webinar Event: 2022 Government Contracts Year-End Review, December 8, 2022, 1:00 pm EST first appeared on SmallGovCon - Government Contracts Law Blog.View the full article
  8. Koprince Law LLC
    Please join attorney John Holtz, as he heads back to his home state of Nebraska, to the Meet the Buyers Conference. This is Nebraska’s premier government contracting conference where businesses can advance their contracting knowledge, connect with other business owners, and network directly with agency representatives and buyers. John will be doing two presentations: joint ventures, as well as size and affiliation issues.
    Don’t miss the chance to meet directly with Federal, State, and Local government agency reps, government contracting industry people, and resource providers and please stop by the Koprince McCall Pottroff table and say hi to John. More information and registration here.
    The post Event: Meet the Buyers Fall 2023 Conference | October 17-19 | Scottsbluff, Nebraska first appeared on SmallGovCon - Government Contracts Law Blog.View the full article
  9. Koprince Law LLC
    Happy Friday, Readers. We hope you have had a great week and are looking forward to the weekend. Talk around the proverbial water cooler, this week, has been about the possible government shut down. On midnight, September 30th, fiscal year 23 will come to an end. Apparently, if certain things aren’t passed by Congress and signed by the President, the new fiscal year will start with a shutdown, and that has a lot of government contractors nervous.
    We have included some articles on this topic and other federal government news below. Have a great weekend.
    Meetings: Regional Small Business Regulatory Fairness Boards DOD Software Licenses: Better Guidance and Plans Needed to Ensure Restrictive Practices Are Mitigated Ultima Services asks court to bar SBA’s 8(a) program in the administrative, technical support industry SBA accused of sidestepping court ruling on race-conscious program FBI to Award Up to $358M in Contracts for Architectural, Engineering & Planning Services How contractors are bracing for a federal government shutdown Contractors prepare for shutdown or at least an austere October Brace for potential government shutdown, federal contractor group warns Minority and women business owners learn, compete at Opportunity Inclusive Business Summit Government Shutdown: What Government Contracting Businesses Need To Know Federal Contracting Program for Women Entrepreneurs Expands Guidelines for Reporting Bundled and Consolidated Contracts GAO union employees keep flexible work options in new contract A messy dispute caught one company for millions of dollars of government refund demands CIO-SP4 protest dismissed after NIH commits to corrective action Pentagon chooses 8 new ‘hubs’ to lead $2B effort to revitalize US microelectronics Navmar to Pay $4.4 Million to Settle False Claims Act Allegations Regarding Double-billing and Cost-Shifting The post Small GovCon Week in Review: September 18-22, 2023 first appeared on SmallGovCon - Government Contracts Law Blog.View the full article
  10. Koprince Law LLC
    Happy Friday, Readers! Now that the holidays are over, we are really enjoying the NFL Playoffs and rooting for our Kansas City Chiefs. There’s never a dull moment when Patrick Mahomes is on the field! Our fingers are crossed that the team can get to another Super Bowl.
    There was a lot of activity in federal government contracting this week and it seems that contract opportunities are really increasing. The U.S. Small Business Administration (SBA) began accepting applications through the Veteran Small Business Certification (VetCert) program to expanding access to resources for Veterans and other underserved populations. You can read the full press release in the article below as well as other noteworthy news articles that we have included. Enjoy the weekend!
    Biden-Harris Administration to Begin Accepting Applications on January 9 for SBA Veteran Small Business Certification Program [SBA] Austin ends the military’s COVID-19 vaccine mandate [FedTimes] GSA Issues RFI to Seek Input from Industry on Carbon Free Electricity Offerings [GSA] Fears of the next government shutdown loom months ahead of deadline [FedTimes] Interior Department watchdog finds 5% of active credentials at agency use word ‘password’ [FedScoop] 5 States Challenged the Federal Contractor Wage Increase and Lost [GovExec] Things seem settled in Washington, but federal contractors are still uneasy [FedNewsNet] How digital engineering models are driving DOD IT development [FedScoop] Inflation costs present both barrier, opportunity for contractors in 2023 [FCW] FAA preliminary investigation traces NOTAMS outage to damaged database file [FedScoop] The review that helps DoD create better contract management documentation [FedNewsNet] NBDC’s Procurement Technical Assistance Center Renamed to Nebraska APEX Accelerator [UNOmaha] Biden administration fends off challenge to higher minimum wage for federal contractors [FedNewsNet] Strengthening Support for Federal Contract Labor Practices [WH] Two Plead Guilty To Conspiring To Traffic Stolen Medical Products From The Battle Creek Veterans Affairs Medical Center [DoJ] The post SmallGovCon Week in Review: January 9-13, 2023 first appeared on SmallGovCon - Government Contracts Law Blog.View the full article
  11. Koprince Law LLC
    Earlier this year, SBA’s Office of Hearings and Appeal (“OHA”) released its first HUBZone status protest appeal decision. That decision, as you may recall was fairly straightforward, resulting in a dismissal of the appeal. About half a year later, OHA has issued its second HUBZone status appeal decision! This one is even more straightforward than the first one, but it is important nonetheless as it now gives us further insight into the HUBZone appeal system. Let’s take a little look.
    In PAE Applied Techs. LLC, Appellant Re: Lynker Techs. LLC, SBA No. HUB-102, 2023 (Dec. 5, 2023), the appellant did correctly appeal a decision on a HUBZone status protest, as opposed to challenging a decision of SBA to decertify, as appeared to have been the case in that first decision, New Source Corp. back in June 2023. It cannot be emphasized enough how important following the procedures are if you want a chance of winning your appeal. We, of course, understand that many of these things seem very minor. For example, in New Source, one of the reasons the appeal was found deficient (and therefore was dismissed) was that it was unsigned and was not properly served to the required parties. But these procedures do have a foundation in real concerns. Signatures are evidence that the party is who they say they are, and service is important because it puts parties on notice that the matter is being challenged.
    However, the biggest issue in New Source was that it was a challenge of SBA’s decision to decertify the company from HUBZone. It did not involve any HUBZone status protest. This is important. As we noted earlier this year, the HUBZone appeal system is only for appeals of HUBZone status protests. It is not a means to challenge any decision about whether a company is or is not HUBZone eligible. We are curious if the protest system may get expanded later, but for now, it’s just for challenging the results of HUBZone protests. Here, PAE indeed appealed a HUBZone protest decision, so OHA did have jurisdiction over the matter.
    Unfortunately for PAE, they made a misstep as well in their appeal. PAE’s appeal challenged a decision dismissing its protest of the HUBZone status of another company, Lynker Technologies, LLC. It appears that PAE, however, did not give a sufficient argument as to why the original dismissal decision was erroneous. Since we lack access to what PAE filed, we do not know what actually was in their appeal. But, as it was, OHA basically gave PAE an ultimatum: Explain why the appeal shouldn’t be dismissed or OHA will dismiss it. PAE chose to withdraw the appeal. When one appeals an SBA status determination or size determination, it is not enough to simply say that one is challenging the decision. Even if SBA’s error is obvious, you have to spell out what the reason for the challenge is in your appeal and it has to have some base logic to it. This goes for essentially all appeals processes.
    In itself, OHA’s decision here does not shed much light on how OHA will actually analyze HUBZone eligibility issues. However, some information can be gleaned. It is quite clear that HUBZone appeals to OHA are not common, at least not yet. In a six-month period, there have been just two, and both ended in dismissal. It is safe to assume that HUBZone appeals will not be common going forward either. We’ll keep our eye out, though. We hope to see a HUBZone appeal decision that actually discusses some of the eligibility requirements for the HUBZone program to help provide some needed clarity on the program.
    Questions about this post? Email us. Need legal assistance? call at 785-200-8919.
    Looking for the latest government contracting legal news? Sign up for our free monthly newsletter, and follow us on LinkedIn, Twitter and Facebook.
    The post A HUBZone Appeal Appears! Continuing our Look at the HUBZone Appeal Process first appeared on SmallGovCon - Government Contracts Law Blog.View the full article
  12. Koprince Law LLC
    Hello, Readers! Many small business contractors and agency personnel are paying close attention to the fallout from the recent court decision on the 8(a) Program, as shown in this week’s articles. For an explanation of the decision, see the post from John Holtz, while Nicole Pottroff has explained SBA’s pause on taking current 8(a) Program applications. Another big story was DOL’s new rules.
    We hope you have a wonderful weekend and please refer to our most recent blog posts for additional information on federal government contracting matters.
    How to inoculate your agency’s acquisitions against protests DHA faces legal challenges to how it conducted $2.5B procurement One of SBA’s signature contracting programs is on hiatus Three ways the proposed NDAA could change the way contractors do business State Department providing extra cyber-supply chain risk training for 150 contracting officers 5 Companies Win Spots on $100M Air Force ISR, Cyber Support Contract Small tech companies ask Congress for changes to make acquisition easier to navigate A forest of proposed rules sprouts up around federal acquisition A state official calls on GSA to reopen its multiple award schedule Harris touts new prevailing wage rule for construction projects Labor Department now has better ability to dig into discrimination claims against federal contractors GSA’s commercial platforms gaining steam, but data, other concerns persist Amphenol Corporation Pays $18 Million To Resolve Allegations That It Submitted False Claims For Electrical Connectors US Department of Labor Announces Final Rule to Modernize Davis-Bacon Act The post SmallGovCon Week in Review: August 7-11, 2023 first appeared on SmallGovCon - Government Contracts Law Blog.View the full article
  13. Koprince Law LLC
    John Holtz was recently interviewed by Dr. Kizzy Parks with K. Parks Consulting, Inc. about the current 8(a) Program situation and the pause on applications. Please use this link to access this informative podcast and we invite you to visit YouTube for all of Kizzy Parks podcasts concerning federal government contracting matters.
    The post Podcast: Understanding the 8(a) Lawsuit and Its Impact: Attorney John Holtz Reveals All first appeared on SmallGovCon - Government Contracts Law Blog.View the full article
  14. Koprince Law LLC
    Happy Friday, Readers! Hope you have been having a great week and a great start to February! Around these parts, we’re getting geared up for another exciting Super Bowl with our hometown Chiefs and the anticipation is building.
    We hope you had a great week and our looking forward to a very nice weekend. We have included a few articles of interest concerning federal government contracting below. Of special note is a new contract management standard and a priority for small business engagement in DoD contracts. Enjoy!
    Defense Federal Acquisition Regulation Supplement: Update of Challenge Period for Validation of Asserted Restrictions on Technical Data and Computer Software (DFARS Case 2022-D016); Extension of Comment Period [FedReg] Tampa Man Sentenced To Over Three Years In Prison For Fraudulently Using Federal GSA Smartpay Account Numbers [DoJ] Increased contract spending a boon for small businesses [FedNewsNet] Civilian federal agencies to adopt new contract management standard [FedScoop] DOD instructs acquisition teams to prioritize small business engagement over best-in-class contracts [FCW] DOD Announces the Establishment of the Defense Management Institute [DoD] Guidance on Awarding Cost-Reimbursement Contracts [DoD] Prompt Payment Interest Rate; Contract Disputes Act [FedReg] Big questions continue to swirl around CMMC in 2023 [FedNewsNet] GSA to start collecting letters of attestation from software vendors in mid-June [FedScoop] House lawmakers want VA’s $20 billion-plus electronic health record program to improve or else [FCW] DOD’s open cyber recommendations date back to 2012 [FCW] Industry voices complaints over short response window for $60B VA recompete [FCW] The post SmallGovCon Week in Review: January 30- February 3, 2023 first appeared on SmallGovCon - Government Contracts Law Blog.View the full article
  15. Koprince Law LLC
    SBA, like other agencies, publishes a semiannual Regulatory Agenda to provide an update on the various rules it has coming up as well as a timeline for when they will be published or become final. While SBA doesn’t have to meet these timeframes, it’s always good to check in on what SBA has been working on when the final rules will come out. This agenda includes an update on increased size standards, along with some other important rules. Here is a summary of the upcoming rules and what we think could most impact federal contractors. Be sure to comment on these rules if you have an opinions on them.
    Here are highlights from the agenda, along with a summary.
    Proposed Rules
    Affiliation in Small Business Procurement Programs; Women-Owned Small Business Program: SBA will be amending its affiliation rules and Women-Owned Small Business program rules to match up with the 8(a) Program and SDVOSB rules more closely. “These revisions will ensure consistent requirements for ownership and control across SBA’s procurement programs.” The proposed rule is expected September 2023. Small Business Size Standards: Adjustment of Alternative Size Standard for SBA’s Loan Programs for Inflation: This only impacts small business loans, not procurement. But for the small business loan programs (EIDL and 7(a)), SBA will an alternative size standard for loan applicants that do not meet the small business size standards for their industries. The proposed rule is expected August 2023 Final Rule Stage
    National Defense Authorization Act of 2020, Credit for Lower Tier Subcontracting and Other Amendments. The SBA will be issuing a final rule, mainly impacting 13 CFR 125.3, to address how the 2020 NDAA required “SBA to alter the method and means of accounting for lower tier small business subcontracting.” This is a fairly limited change for subcontracting plan credit and SBA expects the final rule to come out in September 2023. The proposed rule was released in December 2022. It set a $750,000 threshold above which a subcontracting plan is required. Also note that “commercial plans and comprehensive subcontracting plans therefore are not eligible to use lower-tier subcontracting credit” and can only rely on first-tier subcontracts. Also, “prime contractors are required to maintain records of the procedures used to substantiate the credit they elect to receive for lower-tier subcontracting.” Small Business Size Standards: Adjustment of Monetary Based Size Standards, Disadvantage Thresholds, and 8(a) Eligibility Thresholds for Inflation: SBA has listed this in its regulatory agenda, even though the interim rule changing these standards was effective December 2022 and the final rule was released in June 2023. Regardless, it’s good to see that SBA increased standards for receipts-based size standards, and economic thresholds for the 8(a) and EDWOSB programs. We discussed this rule on the blog here. There are a number of important changes summarized here that are going to have proposed rules issued or scheduled to go into effect over the next few months. The big takeaway is that there are not that many rules on the horizon. However, with the recent court decision impacting the rebuttable presumption for the 8(a) Program, as we discussed, SBA may be coming up with some new regulations for the 8(a) Program and issuing those soon.
    We’ll keep you updated on SmallGovCon once the final versions of these rules are released, so stay tuned.
    Questions about this post, Email us. Need legal assistance with a GAO protest? Give us a call at 785-200-8919.
    Looking for the latest government contracting legal news? Sign up here for our free monthly newsletter, and follow us on LinkedIn, Twitter and Facebook.
    The post On Deck for SBA Regulations in 2023: Affiliation and WOSB Rule Changes first appeared on SmallGovCon - Government Contracts Law Blog.View the full article
  16. Koprince Law LLC
    Hello and Happy Friday! We hope you had great week and are finishing the week strong today. The SBA and Whitehouse announced that the current administration exceeded its small business goal with a record breaking $163 Billion in federal procurement opportunities. That’s an $8.7 billion increase from the previous year, which is great news for small businesses. You can read more about this and other newsworthy articles below. Have a great weekend.
    Biden-Harris Administration Sets Record-Breaking $163 Billion in Federal Procurement Opportunities to Small Businesses [GlobeNewsWire] Acquisition Excellence: HUD Receives an “A+” Grade on SBA’s Annual Small Business Procurement Scorecard [HuD] TUESDAY: SBA Administrator Guzman, NASA Administrator Nelson to Announce New Federal Contracting Records Set by the Biden-Harris Administration at NASA [NewsWires] Statement from President Joe Biden on Record Procurement from Small Business [Whitehouse] No shortage of ideas for reforming Defense Department acquisition [FedNewsNet] Agencies making ‘substantial progress’ toward higher small, disadvantaged contracting goal [FedNewsNet] DHS is the Largest Federal Agency to Receive 14 Consecutive “A” Grades on SBA’s Annual Small Business Procurement Scorecard [DHS] Small Business Size Standards: Adjustment of Monetary-Based Size Standards, Disadvantage Thresholds, and 8(a) Eligibility Thresholds for Inflation [FedReg] Maryland Defense Contractor Sentenced to Almost Four Years in Federal Prison for Procurement Fraud [DoJ] Electronic Health Records Vendor NextGen Healthcare Inc. to Pay $31 Million to Settle False Claims Act Allegations [DoJ] The post SmallGovCon Week in Review: July 17-21, 2023 first appeared on SmallGovCon - Government Contracts Law Blog.View the full article
  17. Koprince Law LLC
    The Texas South-West Small Business Development Center (SBDC) Network is hosting this upcoming, informative webinar on the Buy American Act. The Buy American Act permits agencies to buy foreign end products only under certain exceptions, such as when domestic items are not available at a reasonable cost. Further, U.S. trade agreements waive the Buy American restrictions for certain products. Please join us to learn more about these rules to include the recent updates. You can register here.
    The post Webinar Event: Buy American Act & Trade Agreements, January 19, 2023, 1-2:00 PM CST first appeared on SmallGovCon - Government Contracts Law Blog.View the full article
  18. Koprince Law LLC
    It’s here–the first ever SBA Office of Hearings and Appeals (OHA) HUBZone appeal decision! Sure, it is a very short decision and a dismissal–in fact, one reiterating some of the limitations of the new appeal avenue. But that doesn’t make it any less important. This is still SBA OHA’s first ever HUBZone appeal decision, only made possible by the SBA’s recent issuance of a new rule allowing HUBZone appeals (again, in limited circumstances). Let’s take a closer look.
    That’s right! The SBA’s OHA has issued its first ever Historically Underutilized Business Zone (HUBZone) appeal decision. OHA’s decision in New Source Corp., SBA No. HUB-101, 2023 (June 27, 2023), was a pretty short read, ultimately resulting in OHA’s dismissal of the appeal. But it will still go down in history as a first, nonetheless. Before we get into the decision, let’s talk a little about recently implemented SBA rule and the new OHA HUBZone appeal avenue it created.
    We previously blogged on this new SBA rule both here and here. So, I won’t go too far into the weeds since you can read all the juicy details in our prior blogs. But in a nutshell, as of May 2023, OHA has jurisdiction to hear appeals from adverse status determination protests for certified HUBZone small businesses. But notably, this jurisdiction is limited. The new rule expressly limits OHA’s newfound jurisdiction for HUBZone appeals to “[a]ppeals from HUBZone status protest determinations under” SBA’s HUBZone Program regulations. So, OHA still lacks jurisdiction to hear other types of HUBZone appeals, including those from HUBZone certification application denials and HUBZone Program terminations.
    In fact, OHA’s first official HUBZone appeal decision, issued on June 27, 2023, reiterates OHA’s limitations when it comes to HUBZone appeals. As OHA explains in its decision, the Appellant in New Source Corp. sent OHA an email aiming to “appeal” SBA’s decision to decertify it from the SBA’s HUBZone Program. But OHA found this “appeal email” to be deficient for a number of reasons. So, it ordered the Appellant to show cause why the appeal should not be dismissed. Relying on an important limitation to the new OHA HUBZone appeal process, OHA said:
    The appeal was also found deficient for: being unsigned; not being served to the D/HUB and other required parties; not alleging any error by the D/HUB; and being sent by the Appellant’s “Marketing Director,” which OHA noted may not even be permitted to represent the Appellant in an OHA appeal. In response to OHA’s show cause notice, the Appellant attempted to correct some of these deficiencies (i.e., providing an official appeal petition signed by its President alleging “negligence” and “lack of assistance and responsiveness from HUBZone support staff”–with some supporting documentation). But it did not address the biggest deficiency: OHA’s lack of subject matter jurisdiction over general HUBZone decertifications.
    Without subject matter jurisdiction, OHA had to dismiss the appeal. Again, SBA’s new rule provides an avenue for HUBZone appeals strictly limited to appeals from adverse status determination protests for certified HUBZones. And as OHA notes in the excerpt above, this generally requires that an appellant be either the protested concern or the protester in such a status determination protest to have standing for the appeal.
    So, even though the contents of this decision don’t seem particularly memorable, it is still OHA’s first ever HUBZone appeal decision. And it reiterates an important limitation on OHA’s HUBZone appeal jurisdiction. So for those reasons, we at SmallGovCon are pretty stoked to see it anyway. We are hoping this is the first in a long line of OHA HUBZone appeal decisions that serve to bring more transparency and consistency to SBA’s HUBZone Program.
    Questions about this post? Email us. Need legal assistance? call at 785-200-8919.
    Looking for the latest government contracting legal news? Sign up for our free monthly newsletter, and follow us on LinkedIn, Twitter and Facebook.

    The post First OHA HUBZone Appeal Debuts on the Docket first appeared on SmallGovCon - Government Contracts Law Blog.View the full article
  19. Koprince Law LLC
    The government contracting legal landscape has gone through many important changes in 2022 and the first part of 2023, including new small business rules, SDVOSB certification requirements, recent domestic preference changes under the Buy American Act, and much more.  In this session we will provide a comprehensive update on the most important government contracting legal changes. This is a “no-cost” Training.  Register here.
    The post UTSA Apex Accelerator Webinar: Government Contracts Legal Update 2023, February 21, 2023, 10:00-11:30am CST first appeared on SmallGovCon - Government Contracts Law Blog.View the full article
  20. Koprince Law LLC
    Happy Friday Readers. We hope you all have had a great week. We are enjoying some milder winter weather here in Kansas and received some much-needed rain. We still have a bit to go before spring, so hopefully we will get a little snow still this winter.
    Enjoy the weekend and we also hope you will enjoy reading the articles below, regarding federal government contracting this week, including what small business contractors can look for in 2023.
    SBA Administrator Guzman: New Census Data Shows Record Pace of Small Business Applications Has Continued Under Biden-Harris [SBA] Class Deviation—Section 890 Pilot Program to Accelerate Contracting and Pricing Processes [DoD] White House memo establishes labor advisers on federal contracts [FedTimes] A Texas military contractor pleaded guilty on Jan. 12 to rigging bids on public military contracts in the state of Texas [DoJ] Veterans Affairs unveils draft for $60B T4NG 2 vehicle [WashTech] A cadre of experts to boost Army, contractors’ management of IP [FedNewsNet] Small Business In 2023: Experts Predict Trends And Challenges [Forbes] Construction Company Owner Sentenced for Fraud in Securing Millions of Dollars in Contracts Intended for Service-Disabled Veteran-Owned Small Businesses [DoJ] Why 2023 is shaping up to be a rough ride for federal contractors [FedNewsNet] OMB, DOL Ask Federal Agencies to Designate Contract Labor Advisers [GovConWire] FDA falls short on IT contract management, watchdog finds [FCW] OFPP bringing all contracting officers under one training, certification standard [FedNewsNet] The post SmallGovCon Week in Review: January 16-20, 2023 first appeared on SmallGovCon - Government Contracts Law Blog.View the full article
  21. Koprince Law LLC
    Partner Nicole Pottroff will be attending and presenting at the the ICBSSHOW in Oklahoma City so please stop by our table to say hello.
    The ICBSSHOW, offers informational sessions featuring experts in government procurement, as well as one day of matchmaking to introduce you and your business to government decision makers. Also, there is access to government agency buyers and policy leaders, prime contractors, and tribal procurement representatives looking to expand their vendor pools.
    The post Conference Announcement: ICBS Show, Oklahoma City, October 23-25, 2023 first appeared on SmallGovCon - Government Contracts Law Blog.View the full article
  22. Koprince Law LLC
    This workshop will focus on teaming agreements and subcontracts which can be essential to winning and successfully performing federal government contracts. Greg Weber and I will explain how to develop, negotiate and administer agreements that are both compliant and effective for both small and large contractors. The presentations will cover both the key rules (such as flow-downs and ostensible subcontractor affiliation) and best practices for agreements that go beyond the bare minimum legal requirements. Please join us! Register here.
    The post Event: Teaming Agreements & Subcontracts Workshop hosted by The Catalyst Center for Business & Entrepreneurship, November 16, 2023, 3:00-5:00pm CST first appeared on SmallGovCon - Government Contracts Law Blog.View the full article
  23. Koprince Law LLC
    We at SmallGovCon are excited to announce this first in a new line of blogs we call Why File. Our firm handles a wide variety of federal procurement and contract litigation matters–from SBA size and status protests to contract claims and appeals, and everything in between. One of the most common and important questions we get in that regard is, should I file? Of course, we can only directly answer that question for our current clients after reviewing the relevant facts giving rise to the potential filing. But through our new Why File series, we will cover some of the most common facts and circumstances that lead contractors to initiate litigation. So, without further adieu, here is the first blog in the series, covering some of the most common reasons contractors file size protests.
    Size protests are a vital and effective tool for promoting small business goals and competition in the federal procurement and award process. If the concept is newer to you–or you just need a refresher–check out this Back to Basics blog on the subjects of size protests and appeals. And if you want a deeper dive into how to file size protests and appeals, check out our handbook. When it comes to the question whether you should file a size protest, we can only provide a direct and specific answer to our clients after a review of the award and awardee at issue. But there are still some common red flags that have historically led contractors to file size protests–and that have even led SBA to agree and sustain in many cases.
    1. The awardee has publicly available information that, under SBA’s size regulations, indicates it may be other-than-small for the contract’s assigned size standard.
    This first reason to file a size protest goes to the most basic of SBA’s size regulations, those explaining how to calculate a firm’s size. In SBA’s words, “[t]o be eligible for government contracts reserved for small businesses, your business must meet size requirements set by SBA[,]” which “define the maximum size that a business — and its affiliates — can be to qualify as a small business for a particular contract.” As SBA’s size regulations explain:
    The size standard for a particular contract is the one that corresponds with the NAICS code assigned to the contract, which you can find here. Once you know the applicable size standard for the contract, you can use SBA’s size regulations to calculate the firm’s size. For purposes of this blog, we will briefly summarize and discuss SBA’s size calculation standards (but we won’t go into too much detail here; so, check out this Back to Basics blog for more information on calculating a firm’s size for purposes of federal government contacting).
    At a basic level, SBA’s size standards are either based on number of employees or annual receipts. To determine number of employees, SBA’s size regulations say:
    They clarify that the firm’s “average number of employees” is used, based on the “numbers of employees for each of the pay periods for the preceding completed 24 calendar months[,]” and SBA counts part-time and temporary employees the same as full-time employees.
    To determine average annual receipts, SBA’s size regulations explain:
    The rule lists a few limited exceptions for what counts as annual receipts and notes that those are “the only exclusions from receipts” SBA will allow. So, “[a]ll other items, such as subcontractor costs, reimbursements for purchases a contractor makes at a customer’s request, investment income, and employee-based costs such as payroll taxes, may not be excluded from receipts.”
    The rule explains, in determining size, “[t]he Federal income tax return and any amendments filed with the IRS on or before the date of self-certification must be used to determine the size status of a concern[.]” And where the firm hasn’t filed a federal income tax return for the fiscal year being measured, SBA calculates the firm’s annual receipts “using any other available information, such as the concern’s regular books of account, audited financial statements, or information contained in an affidavit by a person with personal knowledge of the facts.”
    Based on both size regulations, it is easy to see why an unsuccessful offeror may want to protest an award upon finding public information indicating the awardee’s number of employees or annual receipts exceed the contract’s size standard–or information directly contradicting the awardee’s SAM profile or other representations or certifications of small business size. This could be information on the number of employees listed on a company website, SAM profile, or LinkedIn profile. Or it could be publicly available award and government spending information acquired from SBA’s Dynamic Small Business Search (or DSBS) website, the USA Spending.Gov website, or another reputable federal government contracting website. Since a size protest cannot be based on speculation alone, protesters often collect and use screenshots or print outs of this kind of information to allege that an awardee is too large for the award–and thus, ineligible. And where valid and reputable, such support could even lead to a sustained size protest on that basis.
    Review of the regulatory language in SBA’s size rules also gives rise to our second reason to file a size protest, affiliation.
    2. The awardee has a relationship with another entity or individual that gives rise to concerns about what or who has power to control.
    Both rules for calculating size (employee and annual receipts based) note that a firm’s size must include in its calculations the employees or annual receipts of any acknowledged “affiliates” as well. SBA’s employee-based size regulations explain:
    SBA’s receipt-based size regulations similarly explain:
    SBA’s affiliation rules, also found here (at section 121.103), state:
    Now, what constitutes an “affiliate” is not a simple question–nor does it have a simple answer, as affiliation can be found for many different reasons. Since we won’t get too deep into affiliation here, check out these two Back to Basics blogs covering affiliation generally, as well as the specific types of affiliation. But for purposes of this blog, we will briefly summarize why affiliation matters for purposes of size calculations.
    SBA defines an affiliate as follows:
    As you can see, control is key. If SBA finds that one firm has the power to control another firm, the two firms are affiliates. Such control can be obvious, affirmative control (i.e. the right to make decisions on the company’s operations), or it can be negative control (i.e., “instances where a minority shareholder has the ability, under the concern’s charter, by-laws, or shareholder’s agreement, to prevent a quorum or otherwise block action by the board of directors or shareholders.”). Such control can be exercised indirectly through a third-party–or even, unexercised.
    SBA will look at many factors, including the firms’ “ownership, management, previous relationships with or ties . . . and contractual relationships, in determining whether affiliation exists.” The rule even contains a fallback SBA can rely on to find affiliation where the firms are not considered affiliates under one specific affiliation basis (i.e., common ownership or management, economic dependence, familial affiliation). It says, “[i]n determining whether affiliation exists, SBA will consider the totality of the circumstances, and may find affiliation even though no single factor is sufficient to constitute affiliation.”
    So, this second reason to file a size protest could actually be broken into 10 or so reasons, if we wanted to. For example, just to name a few, many size protests are filed because the unsuccessful offeror finds out or determines:
    The awardee works closely with another firm run by an immediate family member (potential familial affiliation); The awardee gets a substantial portion (70% or more) of its revenue from another firm–or provides a substantial portion of another firm’s revenue comes from the awardee (potential economic dependence); The majority owner of the awardee also holds majority ownership in another firm or firms–even if the ownership is less than 50%, but large compared to the other owners (potential common ownership affiliation); Individuals who manager the awardee also manage another firm or firms (potential common management affiliation); and The awardee simply has so many ties to another firm that it cannot be ignored (potential totality of the circumstances affiliation). Again, this list is far from exhaustive. The only thing that matters across the board is that the size of the awardee, when the employees or annual receipts of all of its affiliates are added on, would no longer be small under the contract’s size standard. So, if you file a size protest that meets the jurisdictional prerequisites (i.e., relies on nonspeculative information or findings), the awardee will get a chance to show that affiliation doesn’t exist (typically, by providing information/documentation to SBA regarding its organization, owners and managers, financials, existing agreements, etc., and by showing that the affiliation factors and/or required control are not present)–or that the affiliation has been severed.
    Notably, SBA’s rules do clearly allow companies to “sever their affiliation” by removing the ties giving rise to such affiliation or–where affiliation is familial–by showing a “clear fracture” of the relationship. In such case, the former affiliate’s employees or receipts would no longer be aggregated.
    If the awardee cannot show that affiliation doesn’t apply or has been severed–and the addition of their affiliate’s size does make them too large for the contract at hand–SBA will find them ineligible and will likely require the contracting agency to rescind or terminate the award. If a size protest leads to a finding of general affiliation, such could affect the awardee’s size standard for other contracts moving forward (unless and until affiliation is severed)–and could even affect any certifications the awardee may hold (i.e., 8(a), WOSB, SDVOSB, etc.).
    Affiliation, as well as SBA’s basic size regulations, also gives rise to the third reason to file a size protest that we will discuss.
    3. The awardee has recently initiated M&A proceedings with the potential to affect its size calculations.
    Affiliation can also be found where a firm has stock options, convertible securities, and agreements to merge with another firm. SBA will essentially treat such agreements as though they’ve already been put into effect under its “present effect” rule. But even where a firm is acquired by another firm or acquires another firm, and affiliation itself isn’t really the issue, the firm’s size could still be affected in a way that makes it ineligible for award.
    Indeed, SBA’s employee-based size regulations explain:
    And SBA’s receipt-based size regulations similarly explain:
    Based on the size regulations, affiliation rules, and present effect rule, even an awardee’s written intent to engage in a business acquisition that affects its size–and thus, its eligibility for a small business set-aside contract–could give rise to a size protest, and even an SBA sustain of such protest. So, often, unsuccessful offerors will file a size protest upon getting word that the awardee plans to acquire another company or be acquired in the future.
    Finally, our last reason to file isn’t based on regulations at all–but rather on a gut feeling.
    4. Something doesn’t feel right and you want SBA to ensure the awardee is eligible for the award.
    Indeed, many a size protest has been filed because the unsuccessful offeror simply has a bad feeling that the awardee is hiding something about its size, organization, or eligibility. And again, so long as the size protest isn’t solely based on speculation, that is ok. While we may not encourage protests based solely on a gut feeling, we are not naive to the fact that gut feelings serve as the basis for many size protests.
    Now, there are SBA protective orders for size appeals that safeguard the proprietary information of the protested concern (where requested and granted by SBA). But many unsuccessful offerors will have their trusted government contracts attorneys file the size protest and eventual appeal to get access to information on the awardee’s size and eligibility. The protester can rely on its counsel, along with SBA, to check if the awardee is eligible for the award.
    * * *
    These are just a few (of many) reasons why unsuccessful offerors file size protests. And a size protest–filed for any reason–is an important part of the government contracting world and process. Size protests, and their resulting size determinations, serve the crucial policies of transparency and fairness and further the nation’s small business contracting goals.
    Questions about this post? Need help filing or responding to a size protest of your own? Or need additional government contracting legal assistance? Email us.
    Looking for the latest government contracting legal news? Sign up for our free monthly newsletter, and follow us on LinkedIn, Twitter and Facebook.
    The post Why File: A Size Protest first appeared on SmallGovCon - Government Contracts Law Blog.View the full article
  24. Koprince Law LLC
    Happy Friday, Readers! Can you believe that February is almost over? I guess that means we are one month closer to Spring. Stay safe if you are in the areas of the country getting pounded by more snowfall. In the middle of the country, the thermometer has been going up and down so much on a daily basis, we just never know what we will get. That’s Kansas for you.
    We have included a few news articles on the federal government contracting issues this week. There is some good thoughts this week on how contractors can approach the debt ceiling standoff, as well as federal diversity and inclusivity goals. Enjoy and we hope you have a great weekend.
    Creating a More Diverse and Resilient Federal Marketplace through Increased Participation of New and Recent Entrants [WH] Federal Awardee Database Integration Falls Short [POGO] DLA Named Agency of the Year for Supporting Nation’s Small Businesses [DoD] Federal IT leaders see ‘critical moment’ in securing systems from fraud [FedNewsNet] The Debt Ceiling Standoff Has Federal Contractors On Edge [Inc] Biden pushes federal agencies to meet diversity, inclusivity goals [FedTimes] Department of Labor to Offer Online Seminars to Educate Current, Prospective Federal Contractors on Prevailing Wage Requirements [DoL] Recidivist Fraudster Pleads Guilty To Fraud, Identity Theft, And Making False Statements In Connection With Andrews Air Force Base Construction Contract [DoJ] US Department of Labor Recovers $3.1M in Wages, Benefits for 3,100 Workers Employed by a Federal Subcontractor Servicing Benefeds Program [DoL] Why so many Federal IT Contracts Fail and what to do about it [BOG] NASA, Air Force contractor to settle with DOJ for $400,000 in False Claims Act case [FedScoop] Pending cloud pilot could get DOD to zero trust in a year rather than five [DefScoop] Rules on Gifts in the Federal Government [FedWeek] The post SmallGovCon Week in Review: February 20-24, 2023 first appeared on SmallGovCon - Government Contracts Law Blog.View the full article
  25. Koprince Law LLC
    Steven Koprince, Govology Legal Analyst and retired founder of Koprince McCall Pottroff will be presenting this webinar which covers the Foreign Ownership, Control or Influence (FOCI) Rules for Federal Contractors, including which contracts are subject to FOCI rules, how does the government evaluate whether a contractor is operating under foreign ownership, influence, or control, what responsibilities does a contractor or potential contractor have to identify and report FOCI concerns, and more. Don’t miss your chance to learn all about FOCI, in plain English! Register here today!
    The post Govology Webinar: Foreign Ownership, Control or Influence (FOCI) Rules for Federal Contractors, Sept. 14, 2023, 1:00pm EDT first appeared on SmallGovCon - Government Contracts Law Blog.View the full article
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