To say that life at a consultancy is ruled by one best practice after another is no understatement. One best practice, in particular, isn’t so much a technique as it is a mantra that guides everyone on our schedule acquisition team: Don’t overlook the smallest detail. An area where this is particularly true is your Dun & Bradstreet (D&B) account and your D-U-N-S Number. For those not in the know, this is a standard business establishment identifier code assigned by Dun & Bradstreet for any organization seeking to do business with the Federal Government. Key components of your GSA proposal are built specifically from the information that this account contains. As such, it is important you perform a few due diligence steps at the start of the GSA process. Here are a few items you should keep in mind: Central Contractor Registration (CCR)

One large source of confusion for GSA contractors can be determining the Country of Origin for offered products. Many people think all GSA awarded items must be made in the USA, but this is not the case. Instead, all products offered on a GSA schedule must be produced in a country that is compliant with the US Trade Agreements Act (TAA). Many countries are TAA-compliant, but one major manufacturing course is not – you probably guessed it, CHINA. This means GSA cannot award any items that are manufactured in China onto your GSA contract. Some contractors have trouble determining the exact Country of Origin, as different components come from different countries or different manufacturing processes are performed in different countries. In cases like this, merchandise originates from the country where it has been substantially transformed into a new and different article of commerce with a name, character, or use distinct from that of the article or articles from which it was transformed. For this language, please see the Federal Acquisition Regulations 52.225-5 for more detail: https://www.acquisition.gov/far/05-10r/html/52_223_226.html#wp1169151

On November 2nd, the U.S. General Services Administration in coordination with the Federal Chief Information Officers Council released comprehensive requirements for the Federal Risk and Authorization Management Program, or FedRAMP, for public comment. This is a huge milestone in the governmentwide adoption of cloud computing services. The security authorizations and continuous monitoring of cloud systems that FedRAMP will provide can be used by agencies to streamline their security process while still providing highly effective security services. FedRamp allows agencies to make use of commonly accepted risk assessment and cyber security evaluation of cloud services. Joint authorizations of cloud providers will result in a common security risk model that can be leveraged across the federal government, ensuring a consistent baseline for cloud-based technologies.

Many of you out there might be thinking to yourself, “There are so many opportunities for people and contractors who have security clearances…Maybe I should get one!” Not so fast—most people don’t realize that there are specific requirements that must be met in order to qualify for a security clearance. I’d like to take a moment to outline just a few of these requirements, the basic levels of clearance, and how these levels are granted. How do I qualify? To be eligible for a security clearance, the following conditions must be met: a) It has been determined by the U.S. government that you’re eligible for access to classified information; and b) you are sponsored by a government entity or a cleared contractor. In order to be sponsored, you must be employed by a cleared contractor (or hired as a consultant) and must be in a position requiring a clearance. These two conditions are important to remember.

With the recent Veterans Day holiday having already passed, I have been giving extra thought to those in the service and wanted to finish up my initial blog covering the effectiveness of Executive Order 13360. To recap, Executive Order 13360 or “the 21 Gun Salute initiative” was implemented by the General Services Administration (GSA) and aimed at meeting and exceeding the 3% federal contracting goal with SDVOSBs. Here’s what I found out. Did Executive Order 13360 work? (Part 2 – The Results) On my last blog I reported that the Department of Defense only spent 1.43% on SDVOSB Prime contractors (1.35% for Subcontractors) in 2009. This was just my first search, however, and was sure I would see much better results from the rest of our federal agencies. I mean, 3% isn’t that lofty of a goal, is it? Well, here’s how the rest of the results looked (Format of the table below is Agency, 2008 SDVOSB Prime Contracting Achievement, 2009 Goal, 2009 SDVOSB Prime Contracting Achievement)

The recent changes to the Women Owned Small Businesses (WOSB) Program were finalized and submitted to the Federal Register on October 7th. After analyzing data gathered from a study conducted by RAND Corporation on the representation of WOSBs in specific industries, the SBA found that 83 industries (segmented by the first 4 numbers in the NAICS code) were either underrepresented or significantly underrepresented. The new WOSB program requirements are only applicable to these industries. The contract value for each WOSB set-aside is not to exceed $5 million for manufacturing and $3 million for all other services and products and the WOSB set-aside requirement for total federal contracting dollars is 5%.