Monthly Archives: June 2020


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