Monthly Archives: June 2023

THREE AUDIT ISSUES SCHEDULE CONTRACTORS SHOULD BE PREPARED FOR

With hundreds of renewals and extensions on the horizon for the GSA Schedules program, pre-award audits won’t be far behind, especially for larger companies or those that haven’t recently been audited.  Here are three current audit focus areas of which contractors need to be aware and prepared for.

1.  Section 889B compliance:  This should come as no surprise to industry given the current market emphasis on cybersecurity.  Companies must be prepared to show that they have recently conducted a “reasonable inquiry” of their systems to identify products Read more

THE SCHEDULES TDR ROUTE IS A GOOD OPTION, BUT IT’S NOT “SET IT AND FORGET IT”

The Transactional Data Reporting (TDR) pilot is a good option for many would-be GSA Schedule contract holders.  The program makes it easier for companies to obtain – and comply with – a Schedule contract.  That does not, however, mean that there are no compliance requirements for TDR contractors.  Companies need to be aware that they are open to an audit or whistleblower action anytime they submit information to a government agency or make a representation about their compliance with various contracting rules.  Companies electing to take the TDR path do not have to submit Commercial Sales Practice (CSP) sheets or agree to a Read more

AI, DATA, MACHINE LEARNING ARE ALL TOOLS, NOT ENDS TO THEMSELVES

The revolution in AI and the reliance on data to drive decision making are key practices in many government and non-government organizations.  Who wouldn’t want tools to assist in making better decisions?  It’s important to remember, however, that these new, or newer, instruments are, in fact, just tools.  Tools can help us do our job more easily but are still no substitute for doing the actual job.  This is important for contractors to consider as they create Read more

THREE THINGS TO KEEP IN MIND, EVEN FOR EXPERIENCED CONTRACTORS

“Been there, done that” is an easy trap to fall into if you’ve been in the federal market for some time.  Traps are harder to get out of than into, though.  Here are three tips for companies to remember to stay on the road to business and out of the complacency ditch.

1.  This is a small market:  While the dollars spent on acquisition are considerable, there are fewer than three degrees of separation in the federal commercial item and service marketplace.  The concentric circles and overlapping networks are substantial.  Maintaining a good reputation is key, including such nagging details such as returning calls or emails, following through on promises, and showing up to where you said you would go.  Also, keep in mind that the person causing you trouble today may be tomorrow’s customer or ally.  This is a market where people know each other’s business. Read more

GSA, CISA, OTHERS TO SEE DEBT CEILING SPENDING CUTS

Unobligated COVID 19 and American Rescue Plan funding will be used to reduce the deficit and cut federal spending as part of the debt ceiling reduction plan that passed Congress late last week.  Carbon-emission and green building funding was spared any cuts, showing what the administration prioritizes.  Federal contractors had expressed concern that IT, service, and other projects slated to be paid for with such money would be lost and, to some extent, it seems as if those concerns were justified.  According to a recent FedScoop article, “Language included in the Fiscal Responsibility Act of 2023 would cut unobligated funds made available to the Federal Citizen Services Fund at the General Services Administration through the Coronavirus Aid, Relief, and Economic Security Act of 2020. It would also claw back unobligated funds appropriated for the Office of the Chief Information officer at the Department of Justice through the same emergency legislation.”  While IT leaders may decry losing money for key projects, federal agencies have traditionally experienced claw-backs of unobligated money when Congress decides to cut spending or re-program funds for new priorities.  Slow action on obligating money, some of which has been available for nearly three years, is not the fault of Congress, either.  It’s difficult to claim that “critical” projects are being placed at risk by the cuts if money has been available across multiple fiscal years.  Also, just because money is being trimmed today, doesn’t mean it is gone forever.  Provisions in the debt bill allow for the possibility of restoring some of the trimmed funds in future Congressional action if a case can be made for such action. Contractors, federal agencies, and their allies in Congress are all sure to try to make such cases for a wide array of projects.  There’s almost always a chance for another bite at the federal funding apple.