Contractors should take note of the GSA Inspector General’s FY’25 audit plan.  It shows exactly where companies can expect the IG to look and the pressure CO’s will likely place on industry as a result of the IG putting pressure on them. The IG announcement states, “(t)his plan anticipates a resource mix using 60 percent of available direct staff for performance audits and 40 percent for contract audits.”  Several areas of the Multiple Award Schedule program will be audited.  This includes Trade Agreements Act (TAA) compliance, the use of data in Economic Price Adjustment (EPA) determinations, and mentor-protégé/JV audits.    The IG consistently places TAA compliance at or near the top of its overall Schedules compliance list.  In addition, secure Read more

Government mission managers consistently complain about the lack of innovation and competition from industry.  Do they, however, take the elevator down a floor and talk to the people in their own offices who create a ceaseless parade of acquisition rules that contribute mightily to the situation?  Contractors complain about the costs new requirements put on their businesses, yet industry used to be much more effective at communicating its concerns with policymakers.  The answers to improving participation and innovation in the government market aren’t complicated, but all sides need to do a better job of speaking – and listening – to each other if desired outcomes are to be achieved.  Reducing acquisition rules, especially those that have nothing to do with the performance of a government contract, is an obvious place to start.  Yet to do that, officials at the appointee level in the executive branch and senior legislators need to stop pushing their own agendas and take time to understand, once again, that there’s no such thing as a free lunch, even if they want the FAR to say so.  Kudos to the FAR Council on this front for setting up a listening session for December 4^th.  We recommend that they invite/coerce their bosses from OMB and key Hill staff to attend.  Rules that do remain should be better tailored to meet specific circumstances.  Not every company should have to invest in “super, ultra, plus” security requirements if they’re selling office furniture, tools, or a host of other commercial items. Communication between industry and government simply has to get better, and by this we mean “real” communication.  It’s still shocking, and not a little disappointing, to see political appointees address experienced industry groups with a pre-packaged recitation of platitudeness talking points.  Talk about a wasted opportunity – and sending a clear message that you’re going to do what you want without taking much input.  Industry must tune up its messaging, as well.  It’s great to tell someone what they want to hear, but sometimes they need to be told what they need to hear, even if that creates potential tension. As far as we know, neither side has been imbued with the ability to read each other’s minds. A better acquisition system is achievable if each side wants it bad enough that they actually communicate effectively.

The Department of Defense is poised to issue one of two final rules governing Cybersecurity Model Maturity Certification (CMMC) requirements.  This rule, which will become effective 60 days after publication in the Federal Register, covers the IT security requirements contractors must have when they handle Controlled Unclassified Information (CUI) or Federal Contract Information (FCI).  An advanced copy of the rule states, “To comply with DFARS clause 252.204-7012, contractors are required to develop a SSP (Systems Security Plan) detailing the policies Read more

It’s a well-established fact that relationships drive federal business success.  The trust built up over time by working together is hard to replicate.  Part of this is knowing what’s on the mind of your federal customer.  If they’re distracted or concerned about a work issue, that could slow the pace of an acquisition or project.  Here are a couple of issues that may be on the minds of your federal contacts right now.

1.  Potential Pay Raise:  Whether in DOD or a civilian agency the prospect for a future increase in pay is being widely written about right now.  There are various proposals to raise military pay, Read more

Congratulations!  You made it to FY’25.  We hope FY’24 was a success.  Your reward for a great last year is to crank up and get started for the year ahead.  Here are three things contractors should focus on now to be prepared:

1.  Work To Smoothly Start Awarded Contracts:  There just isn’t going to be that much new business right now, so instead dedicate extra resources to making sure you launch existing projects well and get out in front of any potential management or fulfillment headaches.  Past performance is an important evaluation point for getting future work and that performance starts now.  Now is also a great time to have discussions about what might happen to that project in the event of a shutdown later this year or in early 2025.

2.  Focus on Compliance & Ethics Training:  The government is operating under a CR for the next 12 weeks.  There won’t be any new project starts for that time, plus many of your federal contacts will take a well-deserved break.  While breaks are a good idea for contractors too, it is absolutely essential for companies to use this time for important training on new rules that shape how you sell and what you must comply with.  More rules = more ways to potentially get in trouble.  No one wants to be the next company to welcome the FBI to their office.

3.  Get Out and Network:  We’ve said before that this time of year is about the best in terms of networking with both government and industry officials.  Meet new people.  Learn new skills. Become a more valuable asset to your company and enhance your career at the same time.  There is at least one federal market-related conference every week between now and early December.  Federal buyers, especially, like to do business with people who make an effort to see and be seen.  Take the family to Hawaii at Christmas.  Doing the important work now prepares you for another great year in government procurement and contracting.