Forget the “juice cleanse” or
whatever diet you’re contemplating to get rid of the “Quarantine 15”, Allen
Federal is challenging all contractors to conduct a thorough review of their
contract files by the 4th of July. This could be the single-most important
project your company can take to ensure that the only fireworks you see will be
the ones you should. It should
go without saying that a complete contract file, including electronic records
of e-mails between contracting officers and your company, internal company
documents and, of course, all award documents and modifications, should be at
the fingertips of your contract manager.
If it didn’t need saying, though, we wouldn’t write about it now. Many companies think they have a complete
contract file, until they discover that records have gone missing and that
there is about as much information in the file as you get from your teenager
late on Saturday night. More than one
company has found that it’s been operating under assumptions, passed down as
oral history, that have little documentation to back them up. That’s a tough position to be in when the
auditor comes knocking. Federal
agencies shouldn’t laugh too hard, either.
Many is the time that the government has had to ask a contractor for
contract file documentation they can’t find themselves. So, now is the time. Take the Allen Federal Challenge and ensure
your contract file is complete!
Legal wrangling continues to delay the implementation
of the DISA DEOS cloud contract, an acquisition managed by GSA. DISA has yet to see one order more than 10
months after award. That’s no record,
unfortunately, as DOD’s JEDI contract has been in litigation on both a pre- and
post-award basis for over two years.
Added to the costs and delays specific to these two programs is a
belief that large Indefinite Delivery Indefinite Quantity (IDIQ) contracts
simply cost too much and take too long to put in place, especially when
technology and solutions change quickly.
What good is a contract that takes less than 30 days to buy from
when the contract, itself, takes five or more years to be useable?
Federal agencies that want agile
acquisition to match their agile solutions are already using faster buying
methods, such as Other Transaction
Authority. Small Business Innovation
Research programs are also growing in popularity, especially when obtaining
cutting edge technology. On the cloud
front, DOD continues to fulfill customer needs through existing contracts that
contain many of the features of either DEOS or JEDI. The fighting over DEOS and JEDI is a side
show as the real work of government proceeds.
Federal acquisition professionals and
their internal customers may decide that the basic large IDIQ model has had its
day. While there
simply aren’t enough acquisition professionals to conduct open market
procurements for all requirements, smaller, shorter-term vehicles may be
developed. We understand the irony of
this since recent efforts have been to trim the number of vehicles, but if
those programs can come on line faster, their popularity may rebound. Another idea is to increasingly use
non-priced contracts. This will
speed the award of larger contracts, but require more work at the customer
agency level.
Contractors with large IDIQ portfolios
cannot assume that the status quo will remain. Recommending solutions to important customers
can help you stay ahead of the game and ensure that your company isn’t caught
with a 1998 contract model when agencies shift to something that fits the
2020’s. You can be part of the change
or play catch up.
Government contractors spend considerable
funds on market research to determine how much government agencies buy of what
they sell, who buys it, and how they buy it.
This is a standard commercial market practice and one that can help contractors
be more efficient in their business development efforts. Unfortunately, the area of discerning
government spending in many areas is much more “art” than “science”. The most frequently used database, the
Federal Procurement Data System (FPDS), will provide one set of results, while
private sector organizations based on that information will provide
others. Run a comparison of GSA Schedule
sales via their Schedule Sales Query and match that against FPDS numbers for
the same search parameters and you’ll get different numbers as well. Despite federal efforts at improving
spend analysis, the fact is that there is no exact data on many items and
services that the government buys. Some of this is the result of the “human
factor” where contracting officers must log in acquisition information to a
FPDS or a specific agency system. CO’s
are not known for having a lack of work to do and its easy for them, as it is
for anyone else, to make errors or skip over some data fields. This can cause frustration among
contractors. Many experienced
companies have, in fact, developed their own programs for analyzing and
determining government spend in the market segments in which they do business. These numbers may be the most accurate
as there is a strong business motive to be as specific and detailed as
possible. Not all businesses, though,
can afford to create their own data.
Until technology catches up with acquisition, many companies will have
to make do with what’s publicly available.
This can be difficult for senior corporate management to understand, but
to use one of our favorite quotes, “this is the business we’ve chosen”.
Alert reader A. Grande of Petoskey, MI writes, “During our company’s
recent move, I found a document titled, “GSA Schedule Compliance Manual –
1998”. I’d never seen it before, even
though we’ve had a Schedule for years.
Should I update it, or just buy it a drink since its over 21?” Very funny, A., but outdated compliance
manuals are no laughing matter. Indeed,
any auditor would take it as a sign that your company isn’t serious about
following the terms and conditions of your contract. Compliance manuals and processes only work if
they’re followed, trained to, and maintained.
Both rules and your workforce change over time. Training needs to be consistent, part of the
on-boarding process for every new hire and annually for your team. Many contractors also have an annual review
process in place to catch potential issues before they become problems and
update any written policies that need it.
Current compliance manuals and training aren’t a 100% guarantee that
your company won’t run into a compliance issue.
Like a flu shot, though, they do reduce the chances that you will get
sick and, if you do, that the case will be milder. Not getting a shot, or keeping your
compliance program up to date, can make you sicker and cost your company plenty
in terms of fines and lost productivity.
Whether a good compliance program will make you feel like the “King of
Staten Island” is problematic, but it is definitely a best practice to reduce
risk and cost.
Allen Federal has experience with all of
these virtual meeting formats – and more! We can train your virtual workforce no matter
where they are. While the
government has relaxed requirements in some areas, compliance isn’t one of them,
so its important that your team get its annual training hours in. Better still: Reduced rates are available since we don’t
have to physically travel to your location!
Contact us today to see what we can do for your team at info@allenfederal.com