This course is designed to explain the rules and requirements of the Davis–Bacon Act.  If you manage, administer, or perform contracts that are covered by the Davis-Bacon Act, you must become familiar with the Act and its prescribed features.  The Act applies to Government contracts of more than $2000.00 for the construction, alteration, or repair of public buildings, or public works. 

Topics

The Davis-Bacon Act and Related Statutes

•  The Contract Work Hours and Safety Standards Act (CHWASSA)
• The Copeland Anti-Kickback Act
• The Miller Act 

Exclusions

Interpretations

Types of Work and Contracts

 Prevailing Wage and Fringe Benefit Requirements

 Application of Prevailing Wage and Fringe Benefit Requirements

Related Acts 

• (FLSA) The Fair Labor Standards Act
• ARRA – American Recovery and Reinvestment Act of 2009

State Laws and Regulations

Learn How To

• Find and navigate the available DOL websites and resources of information. 
• Research and learn how employees are classified for purposes of the Act.
•  Distinguish between services, supply, and construction contracts.
•  Understand and determine the applicable prevailing rates in your work site locations.
•  Evaluate and understand bona fide employee fringe benefits and fringe benefit plans.
•  Analyze and record payroll schedule information and complete record keeping requirements.
•  Prepare for Davis-Bacon Act compliance through audits and check lists.

Dates & Locations

The $1495 registration fee includes breakfast, light refreshments, and course materials. View our registration policies.

Hours

8:00 AM–4:00 PM

Breakfast and registration open at 8:00 AM.

A Federal Contracting Institute® certificate of completion will be provided to all attendees upon conclusion of the class.

This course is recommended for:

• 8 Continuous Learning Points (CLPs)
• 0.8 Continuing Education Units (CEUs)

Questions? Please contact Leanne Shroeder at 703-288-2800 or  lshroeder@centreconsult.com.

Centre’s popular Federal Appropriations Law course has been developed by widely-recognized fiscal and appropriations law experts with first-hand knowledge of the “Red Book” (GAO Principles of Federal Appropriations Law). The course is continually updated with the latest Red Book revisions as well as pertinent case studies, rulings and decisions.

Prior to each course, the instructor and developers review current issues that may impact agency fiscal and payment practices—such as the most recent updates to the Red Book, federal budget issues, and agency payment policies—and incorporate discussion of these special issues into the course.

The course addresses primary theoretical learning objectives, but also imparts practical guidance based on everyday implementation of the laws and regulations. Case studies, exercises and group discussions will be used to illustrate the learning objectives and to assist students in managing the fiscal challenges unique to their environments.

Topics

Legal Framework

• Constitutional basis
• Historical review
• Basic definitions

Life Cycle of an Appropriation

• Budget formulation
• Congressional process
• Enactment of funding gap
• Apportionment and allotment
• Close of fiscal year
• Audit and review

Interpreting Appropriation Language

• Line item vs. lump sum appropriations
• Effect of budget estimates
• Reprogramming and transfer
• Permanent legislation in an appropriation
• Interrelationship of authorization and appropriation
• Application of legislative history
• Continuing Resolutions

Availability of Appropriations as to Purpose

• Necessary expense rule
• Specific purpose limitations
• Entertainment and recreation
• State and local taxes

Availability of Appropriations as to Time

• Bona fide needs rule
• Materials contracts
• Service contracts
• Replacement contracts rule
• Contract modifications
• Year-end disposition of appropriation balances
• Elimination of “M” accounts
• Revolving Funds

Availability of Appropriations as to Amount

• Earmarking language
• Anti-deficiency Act
• Augmentation of appropriations

Obligation of Appropriations

• Recording Statute
• Contingent liabilities
• De-obligation

Payment and Collection

Special Issues (Session is tailored to current fiscal environment and agency needs)

• Interagency Transactions
• Issues Surrounding Sequestration of Funds
• March 2013 updates

Learn How To

Upon completion of the course, students will be able to:

• Understand fiscal policy, rules and regulations and how they interrelate with other agency policies.
• Describe the sequence of events involved in the Congressional appropriation and authorization process.
• Differentiate between appropriation, authorization, allotment and apportionment.
• Describe the steps and guidelines for reprogramming funds.
• Apply legal principles to the appropriations process.
• Identify the limitations of appropriations (as to time, purpose and amount).
• Describe how the decisions of the GAO’s Comptroller General affect the fiscal operations of the Government.
• Describe the process for assessing liability and obtaining relief of accountable officers.
• Identify and mitigate typical mistakes that result in lost or wasted funds.
• Manage funds to maximize their allocation.
• Alleviate bottlenecks in the process from allocation to disbursement.
• Understand and mitigate agency fiscal challenges. 

What Participants Say

One of the best presenters/educators I have ever come across. Obviously, truly enjoys her profession
—Gary Harty, HHS 

Instructor used useful, real-world examples
—James Ferguson, DOE-NETL

Dates & Locations

The $1495 registration fee includes breakfast, light refreshments, and course materials. View our registration policies.

Hours

 8:30 AM–3:30 PM
Breakfast and registration open at 8:00 AM.

This course is recommended for 24 Continuous Learning Points (CLPs). A Federal Contracting Institute® certificate of completion will be provided to all attendees upon conclusion of the class.

Questions? Please contact Leanne Shroeder at 703-288-2800 or  lshroeder@centreconsult.com.

Imagine this:  You’re a commercial company with a great opportunity in the Government marketplace, but you’re worried that you and your subcontractors may face too many costs and risks from compliance requirements and other regulatory hurdles. Now imagine that the Government actually understands your concerns, and agrees to limit these costs and risks under the terms of the prime contract. Sounds good, right? Well, in a recent case before the U.S. District Court for the District of Columbia, UPMC Braddock, et al. v. Harris et al. (March 30, 2013), the Court nonetheless held that the Department of Labor’s (DoL) Office of Federal Compliance Programs (OFCCP) had jurisdiction to enforce equal employment opportunity laws against subcontractors even though the federal prime contract exempted them from such oversight. In doing so, the Court appears to have ratified OFCCP’s ability to impose its compliance programs far and wide.

This case involved several hospitals that had contracted to provide medical services to a health maintenance organization, UPMC Health Plan, which had a prime contract with the U.S. Office of Personnel Management (OPM) to provide health care to federal employees who participate in the Federal Employees Health Benefits Program. As I’m sure many of you are aware, the FAR states that the Equal Employment Opportunity clause is to be flowed down to subcontractors unless the subcontractor has less than $10,000 in federal prime or subcontract sales. However, in the prime contract between the Health Care Plan and OPM, the term subcontractor was defined in a way that excluded providers of direct medical services — and thus the hospitals were exempted from such subcontractor flow-downs. Nonetheless, DoL’s OFCCP sought to enforce equal employment opportunity laws against the hospitals.

This case involves the good old Christian Doctrine, which comes from the 1963 case G.L Christian & Associates v. United States. The Doctrine as it is presently interpreted means that mandatory contract clauses expressing a “significant or deeply ingrained strand of public procurement policy” are considered part of a government contract “by operation of law.” That key phrase — “by operation of law” — means that a contractor has to comply with these mandatory clauses even if they don’t actually appear in a contract, or even if the contractor has never heard of the clause (causing me to sometimes call this the You Need A Lawyer Doctrine).

Whether the hospitals were subject to OFCCP oversight turned on whether they were truly subcontractors under federal law. The Court considered the prime contract’s exemption for medical service providers, but found that this exemption was superseded by two federal statutes and DoL regulations. The Court highlighted the fact that “[DoL], not OPM” was accorded the authority to define the term subcontractor for the purposes of equal opportunity compliance, and DoL’s definition did not exclude medical service providers. Accordingly, the Court held that the hospitals were subcontractors for the purpose of equal employment opportunity laws, and therefore that DoL had jurisdiction to enforce compliance.

Much has already been written and said about this decision, but it’s nonetheless unclear how things will eventually shake out. It is possible for Congress to step in and update the definition of subcontractor to exempt hospitals from compliance regimes, or at least to allow them the benefit of their prime contract’s actual terms. And this is not a foregone conclusion — in 2011 Congress did just that in response to a similar case involving a different federal healthcare plan — TRICARE. Absent Congress’ intervention, it seems only a matter of time before OFCCP will assert jurisdiction over other unsuspecting subcontractors. Health care institutions that offer services through other federal health care plans, such as MEDICARE and MEDICAID, may now be subject to rigorous compliance programs. Together with the costs of implementing the Affordable Care Act, these compliance costs will pose serious challenges for institutions and may even contribute to the rising price of healthcare.

If you have any questions about this case or this area of law, please reach out to me at sramaley@centrelawgroup.com. I’d love to hear your thoughts, and there are many interesting details I’ve had to omit about this case so there would be much to discuss.

Please comment on this post at Centre Knowledge.

Friendly… Cordial… Supportive… Productive. These are words that the Department of Veteran’s Affairs acquisition brass would like their industry counterparts to use when describing their relationship with VA.  But a recent vendor poll shows there is still some work to do. Twice a year, VA asks vendors to rate their satisfaction with the agency’s contracting process. The latest survey, which garnered about 1,300 responses, mustered up a score of 3.0 on a 5-point scale for overall vendor satisfaction. While there has been steady improvement over the three and a half years that VA has been focusing on their Supplier Relationship Management Initiative, vendors still have concerns:

• Consistency.  Vendors expressed frustration with the way the contracting process varies from office to office within VA. Tom Burgess, Associate Deputy Assistant Sec, Logistics and Supply Chain Management says the agency is trying to break out of the old adage “If you’ve been to one VA contracting shop…you’ve been to one VA contracting shop.” A lot of work has been done trying to simplify the acquisition policy framework so contracting officials in the field will have standing guidance.
• Management of technical requirements. This is another consistency issue. VA says improvements have been made in the IT and Construction sectors, but improvement is still needed in VHA medical care. The agency is trying to build a better infrastructure and invest in staff to better manage requirements. VA’s goal is to replace 150 different local requirements with a standard, baseline requirement that can be tailored to meet local needs. “We are much better at the big buys,” says Burgess. “Local contracting is still ‘hectic’ – there are many last minute buying decisions and adjustments.”
• Improved use of best-value solutions. Vendors always want to sell their best solution, however best value doesn’t always make good business sense, says VA. If the requirements do not call for the “best”, then a low price technically acceptable solution may be more feasible, says Burgess.
• Problems and frustration with FedBid. While it is not mandatory, VHA field offices are asked to use the tool or document the reason for not using it. Ordering agencies should be able to work with the vendor on these issues, which are typically not due to the system, but the information going into the system.
• Manufacturers or distributors: who is going to get the business? Jan Frye, Deputy Assistant Secretary, VA Office of Acquisition, says VA is not trying to create a network of distributors. But there are certain products that are only sold through distributors. For example, Microsoft and some other high-tech producers don’t sell directly to the government – they only go through distributors. So VA “will go through them when required, but we prefer to buy directly through manufacturers,” Says Frye. “Paying 2 overheads, 2 G&A and 2 profits takes money away from the veterans who deserve it. We are not going to artificially stand up distributors to give business opportunities if there is no value added,” he adds.
• Improving VA/FSS lead time.  While VA has “significantly improved” according to Frye, lead time is specific to each procurement. If the vendor doesn’t provide the correct information, it will take longer. Also, there have been several reorganizations which he hopes will improve Procurement Acquisition Lead Time (PALT). This is a top priority, according to Frye.
• Sole source contracts going to VOSBs and SDVOSBs. While VA has unique authority to sole source to VOSB and SDVOSB for contracts under $5 million, there is a hierarchy of review within the acquisition organization. Contracting officials have to make sure the value of the sole source does not outweigh the benefits of competition. Competition helps determine price reasonableness and increases the supplier base.

Another VA initiative: cracking down on credit card purchases.  While the card is useful, it doesn’t always reflect smart buying. Repetitive micro-purchases are not efficient. VA wants to maximize buying power by pooling repetitive purchases to negotiate better pricing. They will also being enforcing the credit card thresholds very strictly – the purchase card is for buys of $3,000 and under only.  “The purchase card is a payment method, not a contract. If it’s above $3,000, it needs a contract,” says VA. The goal of the Supplier Relationship Management Initiative is for VA to engage with their business partners and collaborate about more than just contracts. They are trying to improve their business processes. If you’ve got some vendor feedback for VA, you can send it to: VASRMfeedback@va.gov

Please comment on this post at Centre Knowledge.

For most vendors participating in the federal market, teaming with other vendors to pursue specific contract opportunities or a class of opportunities is a basic fact of life. There are a variety of sound reasons why firms team together (complimentary capabilities, small business subcontracting goals, special relationships with customers or each other) such that I would think that it is safe bet that at least 95% of all federal vendors eventually end up in a teaming relationship of some kind to pursue new work. But what does it really mean to be in a teaming relationship? Are the parties merely going out on a date to see how it goes or are they actually committed to a relationship if the work is won? The answer to that question is resolved by the nature of the written agreement entered into between the teaming parties (and yes it should go without saying that a written agreement is called for if parties are actually going to expend effort to pursue contract opportunities as a team!) Put most simply – the more specific a teaming agreement is with respect to how a subcontract will be established and how actual work will be performed by the teammates, the more binding the agreement becomes. In fact, for the agreement to be binding at all, it needs to demonstrate that the parties intend to be bound.

This reality was brought home by a recent decision by U.S. District Judge James Cacheris in the case of Cyberlock Consulting, Inc. v. Info. Experts, Inc., 2013 WL 1395742 (E.D.Va., April 03, 2013). The case is instructive because it establishes both what to do and what not to do if the parties desire to enter into a binding teaming agreement. Specifically, Cyberlock teamed with Information Experts (IE) to pursue multiple contract opportunities with the U.S. Office of Personnel Management (OPM). Their initial endeavor was quite successful. Based on the parties’ teaming agreement, which specified exactly what work would be performed by each party if they were successful and included as an attachment an actual subcontract that would be executed if the award went to IE, IE won the prime contract and Cyberlock promptly was awarded the subcontract contemplated in the teaming agreement. Everyone was very happy. But then strangely, when it came time to bid on additional work for OPM, the parties entered into quite a different written teaming agreement – one in which there was no identification of the work each party would perform. Instead the agreement simply stated that IE would perform 51% of the work with its employees and that the parties would negotiate a subcontract to enable Cyberlock to receive the remaining 49%. Given these vague terms about who would be doing what, no contemplated subcontract was attached to the agreement. Furthermore, this new teaming agreement (which expressly stated that it superseded all prior agreements between the parties) confirmed that that it would terminate if there was “a failure of the parties to reach agreement on a subcontract after a reasonable period of good faith negotiations.”

You know what happened next – the parties did not agree on the terms of a subcontract and IE kept all the work. Cyberlock subsequently engaged legal counsel and filed suit to recover damages for alleged breach of contract. The result – Cyberlock lost. Why? Because under Virginia law mere “agreements to agree” are not enforceable and the Court viewed the teaming agreement in issue as constituting an agreement to negotiate, not an agreement to be bound. In other words the parties were merely “dating” and had not entered into a committed relationship.

Admittedly this case turned on the interpretation of Virginia law by a federal court sitting in Virginia. Might the result have been different if it had been heard in another jurisdiction? Possibly. But who needs the anxiety and aggravation of testing these limits? If you want to team with others and have a binding commitment if the team is successful, then spend some time and effort on crafting an effective and meaningful teaming agreement! Does that agreement need to include or attach the text of the actual subcontractor? In my experience no – but that would not be a bad thing to do if possible. At a minimum the scope of work and pricing associated with that subcontract should be established in the teaming agreement and the basic terms of the subcontract agreement should be defined or referenced. The bottom line is this – the more time and effort you expend in preparing your teaming agreement and crafting and tailoring its terms to the specific engagement you intend to pursue the more likely you are to be rewarded at the end of the process.

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A few weeks ago the General Services Administration (GSA) identified a security breach in the System for Award Management (SAM). Registered SAM users with entity administrator rights and delegated entity registration rights had the ability to view any entity’s registration information, including both public and non-public data at all sensitivity levels. Registrant’s data such as user names, Taxpayer Identification Number (TIN), Social Security Number (SSN), and bank account numbers were potentially viewable to others.

Upon identifying the issue, GSA sent all SAM users an e-mail explaining the situation and that they were working to fix it. For those registrants whose confidential data had been potentially viewable to others, GSA sent a separate e-mail to them informing them that GSA would provide credit monitoring resources available to them at no charge. GSA stated in the e-mail that “Registrants using their social security numbers instead of a TIN for purposes of doing business with the federal government may be at greater risk for potential identity theft.”

Due to the security breach, some components of SAM were temporarily shut down so that GSA could conduct their investigation and begin strengthening security measures to ensure that this will not happen again. Up until March 25, SAM users were unable to register or update an entity record.

The purpose of SAM is to streamline the federal government contracting process by incorporating multiple databases into one. Currently, SAM incorporates the Central Contractor Registration/Federal Agency Registration (CCR/FedReg), Online Representations and Certifications Application (ORCA), and the Excluded Parties List System (EPLS) into one database.

The security breach is by far the worst issue that SAM has encountered since its implementation in July 2012. However, as you can tell by the many other articles I have written in regards to SAM, users have experienced many other issues as well. Some of these issues include a busy signal when calling the helpdesk and being put on hold for an hour or more at a time. Due to this security breach, one can’t help but point out the obvious: SAM is delaying vendor’s ability to do business with the government versus streamlining this process.

If you have questions concerning the security of your SAM account, please visit GSA’s FAQ. If you have questions regarding the credit monitoring provided by GSA please visit here. And if you would like to swap “war stories” or validate some problems or concerns you have regarding SAM, feel free to contact me at cclokey@centreconsult.com. Hang in there!

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If you are going to steal, steal big. And that’s exactly what Kerry Khan did. Army Corps of Engineers program manager Khan was the mastermind in the largest bid-rigging scheme in the history of federal bid rigging. He and his fellow conspirators make it into the “federal hall of shame” with their $30 million dollar take. He spent a lot of it on liquor, fast cars, and fast women and the rest he just frittered away.

Those of you looking at your 401(k) statements and thinking you will be working until you are 150 years old, probably wonder, “How do I get some of that”? Well not so fast. Khan could spend as much as 21 years in prison. He pled guilty in 2012 and is now awaiting sentencing this July.

Here’s how the scam worked. Contractors involved in this scheme submitted bogus invoices. Khan or one of his associates in the government approved those invoices. The Army then paid them. The money from those invoices went to kickbacks and payoffs to various businesses which were either owned by Khan or eventually funneled the money to him. The scheme operated under the aegis of a big Army Corps contract called Technology for Infrastructure, Geospatial and Environmental Requirements (TIGER). To date at least ten defendants have pled guilty to charges such as conspiracy to commit money laundering, bribery and kickbacks.

So how did such a fraud continue unchecked for so long and to such a high dollar amount? A spokesperson for the Army Corps said that the Corps is reviewing policy and procedures related to the acquisition process. You think maybe? In honor of Khan and the Corps I have written this limerick:

There once was an Army PM
Who engineered quite a fraudulent gem
It involved bribery, kickbacks and more
(All that extra shopping became quite a bore)
Until the judge said, “prison for him”
That’s what happens when you cheat and skim.

If despite my limerick, you still want to read more about Kerry Khan and his exploits go to either The United States Attorney’s Office, District of Columbia Press Release or Federal Times. And no, I won’t quit my day job to write poetry.

I hope to see you at our MAGIC conference in July or you can hear me speak about the exciting world of Service Contract Act contracting at the NCMA World Congress.

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As many of you know, GSA has been hard at work on its next generation contract vehicle for professional services – OASIS (One Acquisition Solution for Integrated Services). OASIS is being proposed as two separate procurements, one unrestricted and one restricted to small businesses (OASIS SB). The draft RFPs are significant not only because the procurements themselves are significant ($6 billion each over ten years) but also because they provide insight into GSA’s thoughts on how procurements for complex services should be solicited, executed and awarded in the future. In other words, the OASIS RFPs reflect business models that we would expect GSA and other agencies to follow in the future.  Consequently, we at Centre thought we should share our impressions, both favorably and unfavorably, regarding the models and methodologies GSA has embraced in the OASIS draft RFPs. Given the release of the draft RFPs coincided within a week of the passing of legendary cinema critic Roger Ebert, what better way to provide those impressions than with some good old “thumbs up” or “thumbs down!”  

1. Contract Scope Definition – We like this. OASIS recognizes the reality that a great many federal agency requirements for professional services cut across business disciplines. One contract vehicle that enables agencies to acquire integrated professional services based on the demonstrated expertise of vendors in providing or building teams to deliver integrated services makes a lot of sense. 2. Contract Structure – This is a bit convoluted but there is definite method to GSA’s madness. Offerors may submit offers in up to six “pools” per contract, with the pools grouped around services classifications or NAICs that share common size standards, such as NAICS with a $14M annual revenue size standard to NAICs with 1,500 employee size standards. To qualify in a particular pool, vendors will have to demonstrate capabilities relative to a NAICs covered by the common size standard. Why do this? To have a meaningful ability to maintain small businesses on the contract over the life of the contract! On the OASIS SB procurement, if a contractor comes to exceed the size standard applicable to the pool under which it originally qualified, they are eligible to laterally “on-ramp” to the next highest pool under which they will still be eligible to qualify as a small business. Without these features, OASIS SB would be at risk of running out of vendors that still qualify as small businesses after the first five years of the contract. 3.  Number of Awards – GSA proposes to award 40 contracts in each of the six vendor pools provided for on each contract. That’s a lot of awards. It would be interesting to gain more insight as to how that many seat holders by contract pools is optimum. We suspect that fear of protests is the prime motivator for this number. 4.  Evaluation Standards – Mixed. We like the initial pass/fail evaluation of offers. That allows offerors that don’t meet the minimum standards in the minds of GSA to be culled from the field early. Offerors can protest their elimination but it will not hold up the ultimate contract because GSA must still perform more detailed ratings of the remaining offerors. GSA’s proposed use of a numerical rating system in performing those detailed ratings may be problematic. In our experience numercial rating systems are more easily protested because numerical scoring errors are much easier to establish than challenges to adjectival ratings. 5. Teaming – Teaming for purposes of the OASIS RFPs is prohibited. Instead, offerors are required to demonstrate their experience in assembling high performing teams to provide integrated professional services solutions. This is smart because on past major procurements, vendors have spent too much time developing teaming arrangements for the RFP which may never get used in performing future task orders. 6. Contract Types – OASIS provides for all three major contract types – FFP, Cost Plus and T&M. We suspect that T&M will not get used much, which makes the effort required under the RFP to develop T&M rates to be annoying, but many federal customers (particularly at DOD) want a contract vehicle that provide for cost reimbursable contracting for non-R&D services. OASIS fits that bill. 7. Standard Labor Categories – The OASIS RFP requires offerors to perform an elaborate process to map their proposed labor categories to labor categories defined in the Department of Labor’s Standard Occupational Categories (SOCs). The goal of this process is clearly to equate labor category descriptions across all vendors. GSA has been chasing this goal throughout the discussions leading up to OASIS, apparently because some at GSA are committed to a brand of strategic sourcing for professional services. The problem with this model on OASIS is that there is no guarantee that vendors will perform this mapping in the same way, which makes the resulting standards uneven. Furthermore, the RFPs allow offerors to deviate from their standard categories on individual task orders. Plus, no one is supposed to be doing T&M ordering anyway. Seems like a lot of effort for little gain. 8. Small Business Contracting – Mixed. As noted above, we really like both the lateral ramp (upgrading small business for the next highest pool when they outgrow NAICS) and the vertical ramp (upgrading small business that outgrow all applicable NAICS to the unrestricted contract) features. It’s a great way to allow small businesse to maximize the benefit of this contract as prime contractors. We are not, however, wild about the 50% small business subcontracting goal on the unrestricted RFP. That’s a really big number. Heck, GSA comes nowhere close to that number on its small business contracting awards. Why is it reasonable to expect vendors to be able to do that much better? You are free to provide GSA with your own impressions on these or other subjects. The period for providing questions to the draft RFP closes next Monday, April 29^th.

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GSA Federal Acquisition Service’s facilities in Arlington, VA/Crystal City will soon be closing and relocated to a renovated GSA headquarters on 1800 F Street in downtown Washington D.C. The renovated GSA HQ facility will nearly double in capacity from 2,500 to 4,400 employees by adding 62,000 square feet.  The good news is that the relocation will enable GSA to move out of high-cost leased buildings and consolidate their office space in the region. The bad news or new twist (depending on your view point) is that FAS employees affected by this relocation will no longer have designated offices, but instead will work in a variety of open settings under flexible workplace policies using the options of unreserved work space, hoteling, or teleworking. Contractors can expect delays through the summer as GSA employees adjust to the new working arrangements. “There will be a seat for every employee at the building, and resident contractors will be able to use work spaces in the building,” the spokesman said. What this means for vendors with GSA contracts, specifically contracts managed at the Crystal City location (Schedules 23V, 48, 70, 71, 520, 599, and 751), is that any contract modification that needs to be done should be squared away now. Also keep in mind, with the IT Acquisition Center relocating, new proposals from new vendors may be delayed quite a bit before being reviewed by a Contracting Officer. It’s clear that GSA is looking to cut spending since becoming embroiled in multiple spending scandals over the past year.  Consistent with this new focus GSA has reformed its travel policies and has already announced cancellations of three major conferences – FedForum, SmartPay Training Forum, and GSA Expo. GSA is also looking to repair its own image and address the new budgetary environment in which it operates, which includes relatively flat schedules but more schedule vendors to manage.  As Acting Administrator of the U.S. General Services Administration, Dan Tangherlini recently affirmed, GSA is embracing “cost savings” as it performs its core mission objectives through money saving solutions such as rent consolidations and bulk buying of products and services through strategic sourcing which by the way, is gaining supports across government agencies. As GSA facilities set to relocate, Contractors should prepare and ensure all their files are up to date and backed-up in case GSA comes back requesting files that GSA may have lost or misplaced during the move-out process. Be prepared and aware of modifications that need to be completed and do it now before the waiting games begin.  Finally we would recommend that vendors affected by this move communicate with their GSA contracting officers and specialists to understand how the relocation and new operating environment will affect their ability to do business and maintain effective lines of communication.

Please comment on this post at Centre Knowledge.