GSA OASIS Draft RFP Series, #3 Contractor System, Compliance and Certification Requirements
Thank you for continuing to follow our special GSA OASIS blog series. Before discussing the requirements on OASIS and OASIS SB for contractor systems, compliance, and certifications, a disclaimer – all posts are based on information from the OASIS draft RFP and the most current information available on the OASIS Industry Community on GSA Interact. Changes are certain to occur between the draft solicitation and the final RFP; Aronson will identify major changes as soon as we are aware of them.
Before making a bid decision, companies must understand that simply meeting the minimum solicitation requirements will not be enough to win an OASIS contract. GSA wants to award to ‘best in class’ contractors, so points are only awarded for exceeding the minimum requirements. Although less than 18% of the total points are currently allotted to to systems and certifications, these could be critical differentiators if the competition is as intense as we expect. GSA stated in the most recent RFP Q&A that it did “not anticipate that many, if any, Contractors will have all systems and certifications that are encouraged. The evaluation process is about distinguishing between Offerors.”
There has been a lot of confusion regarding which systems and certifications are actually required. The purpose of this blog is to summarize what is actually a requirement versus what is merely a recommendation. Continue reading »
Government Contractor’s Domestic Production Activities Deduction Upheld
Generally, to be eligible for the domestic production activities deduction (DPAD), a taxpayer must earn gross receipts from a disposition of qualifying production property. This typically involves a sale and delivery of a manufactured product by the taxpayer to a customer. However, the IRS recently ruled that a government contractor made a disposition for DPAD purposes despite the fact that title to the property reverted back to the contractor (Technical Advice Memorandum 201314043, 04/05/2013). The ruling disposition was not requiring
Continue reading »
Reasonableness of Executive Compensation
Executive compensation is a hot topic and has been widely discussed in industry blogs, presentations, webinars, etc. Our discussion of executive compensation applies to all Government contractors, whether the compensation of their executives reaches the Government compensation cap or not. Previously, we have discussed the current compensation cap of $763,029 and the attempts by the Senate and the President (blog post coming soon) to reduce the cap. Below is a discussion of the factors used to determine what the reasonable executive compensation for contractors should be.
The compensation cap noted above applies when the amount of allowable reasonable compensation exceeds the cap; however, for many small and mid-size contractors reasonable executive compensation will not approach that amount. FAR 31.205-6(b)(2) states that compensation “must be reasonable for the work performed.” Comparison of compensation to other firms should take into account companies: Continue reading »
GSA Eliminates Small Business Set-Aside Designation for AIMS Schedule SINs
The small business set-aside designations are being removed from GSA Schedule 541, Advertising and Integrated Marketing Solutions (AIMS). The Federal Acquisition Regulation (FAR) now authorizes agencies to set aside procurements for small businesses at the task order level of a Multiple Award Schedule (MAS) contract.
This change will affect contractors that hold Special Item Numbers (SINs): Continue reading »
UPDATED: GSA OASIS Draft RFP Series, #1 Size Standard NAICS Pools
UPDATE (5/3/13): One important point I failed to mention is that on OASIS SB, GSA intends to award at least three spots in every pool to the following socioeconomic groups-8(a), SDVOSB, HUBZone, WOSB, and EDWOSB. This does not mean that only 25 of the 40 spots in a pool are available for other small businesses, though. The top 40 evaluation will proceed “blind” to socioeconomic status. If there are not at least three representatives from a particular socioeconomic group in the top 40 for a given pool, additional awards will be made to the next highest rated qualified bidder(s) in that group until there are three.
Welcome to the first post in a special series about the GSA OASIS draft RFP. First a disclaimer – all posts are based on information obtained from the OASIS draft RFP and the most current Q&A available on the OASIS Industry Community on GSA Interact. Changes are certain to occur between the draft solicitation and the final; Aronson will identify major known changes as soon as we are aware of them. Please subscribe to our RSS feed to follow this series and to make sure that you receive breaking information as it happens!
Today’s post will discuss the use of NAICS code ‘pools’ to determine a contractor’s size status and eligibility to bid on OASIS SB. Initially, GSA had intended to base the size standard for OASIS SB on a single NAICS code (541330 exception, $35.5M) based on market research concerning the preponderance of work likely to be awarded under the vehicle; however, a recent rule proposed by the Small Business Administration (SBA) caused them to change this approach. Due to the provisions of Section 1331 of the Small Business Jobs Act of 2010 and concerns about the improper allocation of small business credit under multiple-award contracts, the SBA plans to make significant changes to the FAR. Under the proposed rule, “the contracting officer may divide a multiple award contract for divergent goods and services into discrete categories, each of which is assigned a NAICS code with a corresponding size standard.”
In order to accommodate the probable rule change, GSA Continue reading »
Webinar Follow-Up: Aronson Answers Questions on Attributes of an Adequate Accounting System
As a follow-up to the L2 Federal Resources webinar on “Attributes of an Adequate Accounting System,” Aronson LLC government contracting specialists Nicole Mitchell and Brian Bender have prepared answers to several attendee questions:
Is my contract covered by the Cost Accounting Standards (CAS), and how do I determine the level of CAS coverage (e.g., Full, Modified, Not CAS Covered)?
Click here to download a flowchart that illustrates the method for determining CAS coverage and whether or not your company should be submitting a Disclosure Statement.
Does my company have a robust set of policies and procedures?
At a minimum, your business should have the following written policies and procedures (P&P) in place prior to DCAA review/audit: Continue reading »
Creating, Migrating, and Updating SAM Accounts – Free Webinar 2/26/2013
To help System for Award Management (SAM) users, the GSA/FAS Office of the Integrated Award Environment (IAE) is offering a series of free instructional webinars over the next few months. The first webinar, scheduled for Tuesday, February 26, 2013, is geared toward new federal contractors as well as those who were registered in the legacy Central Contractor Registration (CCR) system. This course will cover essential activities for getting started in and using SAM – including creating a SAM account, migrating permissions from CCR, and updating/renewing existing registrations.
Webinar Topic: SAM.gov – Creating, Migrating, and Updating SAM Accounts
Continue reading »
GSA Online Training Available 24 / 7
The Federal Acquisition Institute courses and modules available on the Defense Acquisition University’s website provide online anytime training to assist with your understanding of GSA Schedules and offer continuous learning points (CLPs) that may count towards your contracting certification and continuing education.
You’ll learn how to effectively use the GSA Schedules program to meet your requirements, use GSA tools to enhance competition, achieve small business utilization, procure sustainable acquisitions and much more. Most courses require passing a test with a 100% score to earn CLP credits.
GSA Schedules related courses include: Continue reading »
Protests Increase for Sixth Consecutive Year
The General Accountability Office (GAO) has reported prospective bidders filed 2,475 protests in fiscal year 2012, a 5% increase over FY 2011. This is the sixth straight year that bid protests have increased and is a whopping 75% increase over FY 2007. 18.6% of the FY 2012 protests were sustained compared to 16% in FY 2011. Yet the effectiveness rate (sustained protests combined with corrective agency action) remained constant at 42%. A significant part of the GAO report was devoted to a disagreement between GAO and the Veterans Administration. The VA believes it has the right to use the Federal Supply Schedules without setting aside the procurement for veteran-owned small businesses. The GAO maintains that if 2 or more small veteran-owned firms can do the job, it should be set-aside. Continue reading »
GSA Webinar: Blanket Purchase Agreements, Dec 6, 2012
GSA’s Multiple Award Schedules (MAS) webinar for December 2012 is on Blanket Purchase Agreements (BPAs). GSA offers a mixture of scheduled webinar, online anytime, and in-person training to help Schedule contractors effectively use the Schedules program to best achieve their desired goals. After the webinar, you should be able to:
- Describe the role of a Blanket Purchase Agreement (BPA) in the MAS program Continue reading »
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- A Marriage of Inconvenience: GSA Schedule Contracts & The Contractor Code of Business Ethics & Conduct Clause
- Emerging Small Businesses: To Grow Your Business, You Must Plan For Growth
- Government Contracting: Look Before You Leap!
- GSA Schedules – Strategies for Success
- New Employee vs. Independent Contractor Considerations
- Pay on Display – Understanding the Executive Compensation and Subcontractor Data Reporting Requirements & Ramifications
- The GSA Schedule: Your Ticket to the Federal Market (May 2010)
- The New FAR Codes of Conduct and Compliance Program Provisions
- The Seven Deadly Sins (of contract compliance)