Monthly Archives: February 2018

THREE THINGS THAT CONTRACTORS SHOULD BE DOING RIGHT NOW

As Congress moves closer to ending “government by CR”, here are three things your company should be doing now to make the last half of the year meaningful:

1.  Work with your customers to understand where money will be spent:  Final appropriations may be coming in a little less than a month. That means new starts and a flood of opportunities.  Smart contractors have started discussions with their customers on when and how that money will be spent once it’s available.  Most of it is already accounted for.  Make sure you’re having those discussions, too, and can help shape opportunities of interest.

2.  Dial down the distraction and stay focused:  A quick read of even the federal market trade press shows that at least editorialists are pre-occupied with issues that have little to do with the business of government.  Don’t get distracted.  We’ll tell you if anything happens you need to pay attention to.  Instead, focus on your pipeline.  Prioritize projects, make sure you have manageable workload and don’t (really, don’t) try to be too many places at once.

3.  Make sure your partnerships are strong.  Acquisition activity will, like Vin Diesel, be “fast and furious”.  One way to make sure you can move quickly – and that your customer can find you fast – is to have your partners as focused and prepared as you are.  Socio-economic partners can help close business quickly, an important factor when there’s lots to do in a short time.  Larger partners could have an edge with your solution.  Make sure your relationships are as strong and prepared as you think.  We’ve been talking about new business since October.  It could actually happen in late April and May.

GSA REPORTEDLY CONSIDERING REDUCTION IN MAS CONTRACT CLAUSES

Two GSA officials have told Allen Federal recently that work is underway inside the agency to reduce the number of contract clauses in GSA Schedule contracts.  The intent is to make it easier to award, manage, and comply with such contracts.   No specific clauses have been mentioned as targets.  Neither has the agency yet requested input from industry on what clauses they might like to see eliminated.  Contractors are expected to have an opportunity to comment on whatever list of recommended eliminations GSA devises.  A number of contract clauses are internal to the agency and have never gone through the regulatory comment period.  Others were never intended to apply to commercial item and service contracts.  Streamlined Schedules could make it the program more attractive to new market entries and potentially encourage existing contractors to add items to their contracts that are not currently included due to management or compliance concerns.  It should be noted that the GSA Office of the Inspector General will also very likely have the ability to comment as well.  As such, we’re not talking about getting rid of everything.  Still, contractors may want to develop their own lists of burdensome or obsolete clauses for GSA to consider

MAIL BAG: CONTRACTORS MUST READ MODS TO ENSURE THAT THERE ARE NO COMPLIANCE SURPRISES

Student reader F. Liebowitz of E. Dickinson College writes, “My company’s GSA contract was recently modified to add new products, yet the document we received back from GSA said that our Basis of Award customer was “all customers”, not what we’d originally negotiated.  GSA knows what our Basis of Award is, right?  Should I got back and fix the mod.?”  Absolutely, F.  You must move immediately to clarify in writing to your CO that your Basis of Award is not “all customers” and cite what the original contract term is.  CO’s inadvertently change contract terms all the time in modifications, whether through inattention to detail, “modification by copier”, or some other error.  It cannot be said strongly enough:  Failure to change this key term back to the original, requires substantially greater compliance from your company and exposes it to substantial risk without a prompt, written, correction.  This is just one example of why it is a best practice to have two sets of eyes review all contracts and mods.  Contractors should not assume that a modification will leave all other terms in place.  Read the mod.  Read the contract.  Make sure that you are 100% sure of your company’s compliance responsibilities.  Otherwise, you could end up with an explosion – with or without a kiln.

HAVE YOU HAD YOUR ETHICS TRAINING LATELY?

It’s a best practice for government contractors to have at least one day a year to stand down and receive ethics training.  Beyond issues like taking your government customer to dinner, there are rules about hiring that customer to come work for you after retirement, hiring their family members, gifts, and even whether rides to the airport are ok.  If your company hasn’t had ethics training lately you need to call Allen Federal.  We can customize an ethics class for your team that can help keep you on the right side of the ethical ledger.  If problems occur and your company hasn’t been trained, it can be a short walk to the suspension and debarment official.  Contact us today at info@allenfederal.com

THE PRESIDENT’S BUDGET IS INTERESTING, BUT IS FAR FROM A BLUEPRINT

Call us contrarians here at Allen Federal, but we think that the usual “all out” discussion of the President’s budget request, submitted to Congress last week, is a bit over-blown.  Certain provisions, such as a wholesale change to low-income food assistance and federal worker pay-for-performance, are simply going nowhere.  Other parts of the proposal for priorities like DOD and VA funding are hardly new.  Perhaps the biggest factor, though, is that unless this Congress gets its act together and passes FY’19 appropriations bills by October, it will be the next Congress that passes final spending bills.  We could, indeed, be looking at a different Read more