Blog

MAILBAG: WAITING FOR THE CO TO APPROVE YOUR MOD

Sometime reader L. Gaga of New York, NY writes, “We submitted a price decrease request to our CO two weeks ago, but haven’t heard back.  Should we keep waiting?”  Interesting question, L.  In fact, we just had this in a recent Schedules class.  The short answer to your question is “no”.  There is usually no reason to wait for formal CO approval on a price decrease, especially if it is temporary or to maintain compliance with your GSA Schedule Price Reductions Clause.  The government likes lower prices.  The key is to ensure that the CO knows that the discount is temporary, if in fact it is, and when normal Schedule pricing will be restored.  On the other hand, you must wait for a price increase request to be approved.  This approval must come from the GSA CO, not a customer agency CO or GSA contract specialist.  Typically, your GSA Schedule price will lag behind your commercial prices.  This is because GSA wants to see evidence that you have billed, and been paid, on the higher amount before they will consider an increase to the Schedule price.  Many companies, though, go years without increasing Schedule prices and then expect to catch up all at once with one modification.  Schedule contracts typically don’t allow for prices to go up by more than 10% in any one year, though.  As such, we recommend setting a calendar reminder to review pricing on a regular basis or trying to “catch up” during your five year extension processManaging your Schedule prices properly helps your company stay in compliance.  Your boss may even exclaim, “A star is born!”

BUDGET DEAL PROVIDES FULL FY’19 APPROPS FOR COVERED AGENCIES

While most national media outlets focused on the border wall issue during last week’s Congressional action, the real good news for contractors is that the legislation provides full funding for DHS, State, Justice and other agencies for the remainder of the fiscal year.  That’s very good news for both contractors and agencies, both of whom had recently been nervously eying the prospect of a shutdown or a “permanent” FY’19 CR.  New project starts may now be possible by the end of March.  That’s about a month earlier than last year and a two month improvement over FY’17.  Budget analysts predict that larger or mission critical projects will still be able to move forward as planned.  It’s smaller or less needy projects that may be pushed to the side.  The compressed time frame, though, does mean that projects that go through assisted acquisition service shops will have to be initiated quickly.  Indeed, all business for the impacted agencies will have to be done in about half a year, though agencies should now be accustomed to that pace given previous year constraints.  Of course, DOD and other agencies that accounted for 70% of discretionary spending have had their funding all along.  Overall, this means that FY’19 should be better for business than the previous two. 

GSA FACES CHALLENGES ON E-COMMERCE PORTAL PROJECT IN LIGHT OF PRICING COMPARISONS

Studies conducted by the Coalition for Government Procurement and Navy Post Graduate School show that prices for certain goods are cheaper – sometimes substantially so, on GSA Advantage than on Amazon Business. The studies were originally reported last week by the Federal News Network.  While the price difference is not a surprise to GSA Schedule supporters, the study findings do pose challenges for GSA and potential e-commerce suppliers as they move forward the e-commerce portal project.  First, it’s obvious that “faster” doesn’t always mean “cheaper”.  Congress was perhaps under the assumption that commercial providers automatically got better deals from suppliers than did the federal government.  If that’s not the case, then a key foundation for e-commerce program is shaky.  Second, the Navy Post Graduate School report did find that buyers preferred the user experience offered by commercial platforms over GSA Advantage.  How/can does GSA work to update Advantage to match that experience?  One obvious answer would be to outsource the operation of Advantage to a third party since GSA likely lacks the funding and resources to upgrade Advantage internally. That option, however, could face internal hurdles.  Third, for potential e-commerce providers, will they be able to lower their prices to more closely match those on Advantage, or at least come close enough so that their total value proposition makes their platforms a viable acquisition method?  If Congress believes that federal agencies will spend more for items than they can get from existing acquisition sources, they may rescind the project. 

All of these issues are in play as GSA drafts a report due to Congress next month on their progress to date in meeting the existing Congressional requirement.  The report will be in the hands of a different party majority than the one that initiated the project and whether they place the same priority on it as their predecessors is unknown.  Whether and how the questions above are addressed will likely shape the future of the project.

A $90B FEDERAL IT MARKET? BLOOMBERG SAYS “YES”, IN 2020

Steady increases in the federal IT budget may result in a total federal IT budget in excess of $90 billion in FY’20 according to recent analysis conducted by Bloomberg Government.  Bloomberg states that IT spending in FY’18 was nearly $65 billion and that IT budgets are currently on a 5% annual upward trend. Overall, IT spending is divided almost equally between civilian agencies and the Department of Defense.  While spending on existing infrastructure is still the largest single area of where funds are allocated, cloud, agile technology, and emerging areas such as AI are all experiencing increased spending.  This is great news for contractors that can offer comprehensive, multi-faceted solutions.  While feds still need equipment, it is more and more the services that come from the equipment that they want, rather than the machines themselves.  GSA officials recently reinforced this with a prediction that almost all IT business will be service-based in the near future.  Larger companies are, frankly, generally better situated to conduct DOD business than smaller or newer market entries.  While DOD leaders do want innovation, many larger projects have at least one established company as part of the team.  The risk-averse nature of acquisition decision making is one thing that hasn’t changed. 

HAVE YOU HAD YOUR ANNUAL ETHICS TRAINING?

Annual training on ethics and contract compliance is an established best practice for government contractors.  Like the flu vaccine, it can greatly reduce (but not eliminate) the impact of any adverse actions government agencies may take against your company if incidences of non-compliance are found.  Training should be mandatory and participation be recorded.  Allen Federal has trained many companies on what to do – and not do – in the pursuit of government business.  Don’t be a contract “anti-vaxxer”.  Get your training scheduled today! Contact Allen Federal at info@allenfederal.com to see what we can do for you.