As part of its effort to expand opportunities for small, disadvantaged businesses, GSA announced last week that it is partnering with the Small Business Administration (SBA) to create a special section of the Multiple Award Schedules program for 8(a) businesses.  The 8(a) Multiple Award Schedule Pool Initiative will create a pool of 8(a) firms that will make it easier for federal buyers to find such firms and hopefully drive more business to them.  Participants in the initiative will receive a designation that indicates their eligibility for 8(a) sole-source awards and competitive set-asides.  According to the joint GSA-SBA press release, “Customer agencies will be able to place 8(a) directed awards once the MAS Solicitation is refreshed and the MAS 8(a) companies are in the pool, beginning later this year.”  The new program could create both opportunities and frustrations for the businesses it is envisioned to help.  On one hand it makes sense to put a pool of 8(a) companies in one place as doing so provides greater visibility.  The speed and price reasonableness of the Schedules Program, coupled with the benefits of the 8(a) program, could make for a fast and flexible way for federal buyers to meet commercial needs and get small business credit at the same time.  On the other hand, the hurdles that businesses of any size must go through to obtain a Schedule contract, including the ability to obtain a fair contract-level price, are well documented.  So, too, is the infrastructure needed to ensure compliance.  These issues extend to current Schedule small business contract holders who already make up the majority of Schedule contractors, a reality indicating that 8(a) firms may not come in for special treatment.  Still, the addition of 8(a) firms could expand the reach of the government’s largest commercial solution IDIQ contract vehicle, something that could ensure better and faster acquisitions overall.

A recent GAO report shows what many contractors already knew:  federal agencies don’t always live up to their FedRAMP responsibilities, even as the federal government expects contractors to do so.  GAO found that four large agencies, including DHS and Treasury, failed to document the authorization of the system and cloud service in use, provide an authorization letter to the FedRAMP program office, or failed to hold contractors accountable for FedRAMP requirements.  These larger agencies, the other two of which are Agriculture and Labor, should have the resources to follow through on the implementation and oversight of FedRAMP Read more

Over the course of the last several years the government has increased the Simplified Acquisition Threshold dollar level, the Micro-Purchase Threshold dollar level, and the dollar threshold at which someone can qualify as an 8(a) company owner.  These increased levels reflect inflation and other market forces.  Despite government flexibility elsewhere, however, the dollar limit on gifts to federal employees remains the same.  Contractors need to remember that there is generally a per-occasion limit of $20 per federal employee and a $50 annual limit on what one federal employ can receive from any single source.  A company is Read more

Federal contractors are increasingly uneasy about a potential default on the federal debt if no deal is reached on increasing the debt ceiling.  One major reason why is that, while a default is not the same thing as a partial government shutdown due to a lack of appropriations, some federal agencies may treat it like one anyway.  Agencies are apparently already having discussions over essential and non-essential workers, just as they would if a lack of appropriations caused a shutdown.  Another difference is that appropriations do exist, meaning that they do have to be spent, or at least firmly committed, during the current fiscal year.  How Read more

It’s hard enough to comply with myriad government procurement rules, even when contractors and their subs get accurate information.  It’s almost impossible to do so when there are dozens, if not more, people offering varying interpretations of what a company does and does not have to comply with in a specific situation.  While the most obvious list of compliance requirements is contained in specific contracts, not everyone reads those all the way through, especially the part about “clauses included by reference.”  They should.  Even, then, however, companies must also deal with the Christian Doctrine which essentially says Read more