On March 31, 2022, GSA released the 10th refresh of the Multiple Award Schedule (MAS) Solicitation. This is important news for contractors—all contractors have 90 days to accept the Mass Modification from its release to formally incorporate all the changes in their GSA contracts.
In a recent blog, we break down everything you need to know about this refresh including raising the federal minimum wage for federal contractors and addressing the allowability of remanufactured items under certain Special Item Numbers (SINs). GSA has also revised the titles and descriptions of several SINs which could affect your current offerings, or what you plan to add to your Schedule in the future. It’s important you understand all the changes in the Solicitation Refresh before you accept the Mass Mod. Check out or blog for a full overview of all the MAS Solicitation updates.
Couldn't make it to last month's webinar? Watch it here on demand. In this webinar, we’ll help you navigate the Small Business Subcontracting Plan process.
Gain an understanding of how to use SBA’s loan programs to get money for your business. Define the Who, What, Why, and How for your business and break down your business idea into nine building blocks. Register here.
This interactive webinar will focus on MAS pre-award and offer preparation. Hosted by a GSA acquisition professional, this webinar will review key elements of the eOffer process and will also provide an open forum for attendants to seek additional clarifications from expert GSA contracting personnel. Register here.
As part of the Money Smart Series, this webinar expands on using the SBA’s loan programs as an asset to your business model. This webinar expands on using the SBA’s loan programs as an asset to your business model. This installment in the series will help you understand why record keeping is important and how it helps your company stay compliant and competitive. Register here.
Under the Trade Agreements Act (TAA), GSA Schedule contractors are required to provide items that are "wholly produced or manufactured" in the United States or a Designated Country, or that were "substantially transformed" into a new and different article of commerce in the United States or a Designated Country.
This webinar will help explain the TAA, identify common issues, and offer best practices for compliance. In this webinar, we'll discuss:
What is the US Trade Agreements Act (TAA) and why is it important?
What is a TAA Designated Country and what is not?
Differences between the TAA and the BAA (Buy American Act)
Determining Country of Origin (COO) and "substantial transformation"
Who has authority? U.S. Customs & Border Protection and CROSS Rulings
Inventory Self-Audits and Manufacturer updates
GSA Schedule Letter of Supply, the Price Proposal Template, and your Supplier Agreements
TAA compliance for Services? Yes!
The risks of non-compliance and the False Claims Act
Maintaining Compliance: April is a Reporting Month
One of the most important aspects of having a GSA contract is keeping and maintaining compliance. Depending on your pricing structure, your contract is subjected to quarterly sales reporting. April is a reporting month meaning your sales are due as well as the Industrial Funding Fee (IFF). For businesses under Transactional Data Reporting, you are still following the monthly reporting structure. You can file your sales data on the Federal Acquisition Service (FAS) Sales Reporting Portal (SRP) website. GSA uses this portal to collect the IFF, the portion of your sales which goes back to the agency.
If you have a GSA contract and are designated as an “Other Than Small” business, another important aspect to compliance is your Small Business Subcontracting Plan. It’s important to note that the deadline for Individual Subcontract Reports (ISR) and Summary Subcontract Reports (SSRs) has been extended from April 30 toMay 10. This extension is to ensure that your company submits a complete and accurate report to GSA.
QUICK TIP OF THE MONTH
Upgrades to GSA eBuy
This month, GSA eBuy is making significant changes to user accessibility. First, instead of having to enter each individual line item when responding to an RFQ, eBuy is going to allow buyers to upload their line items via a single spreadsheet. This new feature will allow sellers to download a line-item spreadsheet and enter prices, re-upload and attach to their quote. Hopefully, this change will make the platform more use friendly and allow sellers to keep their offerings up to date easily.
Secondly, there has been some confusion about the use of $0 on a quote and what it really means. Moving forward, buyers and sellers should interpret an item offered at $0 as included at no additional cost to the buyer. If sellers leave the price blank, it indicates they do not wish to provide a quote for an item. More information about the upgrades can be found here.
EMERGING BUSINESS OPPORTUNITIES
DHS National Architect & Engineering Services Multiple Award IDIQ Re-procurement
The Department of Homeland Security National Architect & Engineering Services has issued multiple award IDIQ sources sought notices to identify potential businesses capable of providing professional Architectural/ Engineering (A/E) Services for Government-Owned/ Leased Facilities. This opportunity is under NAICS 541330 - Engineering Services. Responses are due April 29, 2022, at 5:30 pm EST. More information can be founder under Notice ID 2022_DHS_National_AE.
Durable Medical Equipment (DME) Medicare Administrative Contractor (MAC)
The Centers for Medicare & Medicaid Services (CMS) has issued a pre-solicitation seeking specified health insurance benefits administrative services. This opportunity is listed under NAICS 524114 – Direct Health and Medical Insurance Carriers. Responses are May 02, 2022, 11:00 am EST. More information can be found under Notice ID 75FCMC22R0002.
Polaris GWAC Small Business Pool
GSA has released the Request for Proposal (RFP) for Polaris, a Governmentwide Acquisition Contract (GWAC) focused on IT services and IT service-based solutions. This vehicle will be a total small business set aside with the first two pools focusing on small businesses and Women-Owned Small Businesses. The primary NAICS Code is 541512 - Computer Systems Design Services. Responses are due by May 13, 2022, at 4 p.m. EDT. More information can be found under Notice ID 47QTCB22R0001.
FREQUENTLY ASKED QUESTIONS
Q: What is Suspension and Debarment?
A: The suspension and debarment process is the method GSA uses to eliminate fraud, waste, and abuse in the procurement process. Suspension is a temporary exclusion from federal contracting activity and is used during an ongoing investigation or legal proceedings rather than as a final step. If the investigation shows malfeasance or fraud on the part of the contractor, they will likely be debarred. Debarment is an exclusion that lasts for a specific period of time, usually 3 years, but ultimately determined by the assigned Suspension & Debarment Officer. Debarment is a final decision based on the findings of an investigation or legal proceedings.
Q:What happens if my company is suspended or debarred?
A: Your company will be marked as ineligible in SAM.gov, meaning purchasing agencies will be able to see that you are suspended or debarred. You will also be ineligible for new offers or contract awards and renewals of existing contracts. Prime contractors won’t be able to award you a subcontract greater than or equal to $35,000 unless they have a compelling reason. You also will not be cleared to work as a subcontractor by the government. You will be unable to conduct business with the federal government as a representative of other contractors, and your affiliation with any organization doing business with the government will also be examined.
Q: How can you avoid suspension and debarment?
A: After familiarizing yourself with the suspension and debarment process and its potential causes, the first thing you should do is establish your company’s ethics and compliance programs. Based on an assessment of factors particular to your company, such as industry and location, you’ll also want to establish a system of routine audits in high-risk areas. You should also check SAM.gov’s Exclusions search to make sure your employees are not excluded through suspension or debarment. In addition, you’ll want to designate a Compliance Officer to be a resource on your company’s procedures. Many other steps are those you may already be taking such as conducting background checks, ensuring open channels for employees to communicate concerns, addressing misconduct in your company, and vetting any partners or subcontractors.
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