Many contract compliance problems start small. A miscalculated payment here, a discount not extended there. Many companies figure they’ll just take care of it “later”. As with medicine, though, ignoring the early signs often means up your company can end up in the compliance ER. Small problems don’t have to become big issues, though. Allen Federal can help your team check for cracks, and recommend small fixes before an audit wave floods your contract basement. Make sure you’re compliance program is as healthy as your business. Contact us at info@allenfederal.com.
Recent discussions we’ve had with contractors and contracting officers indicates that federal business is in full-swing. We are now officially in the last quarter of the fiscal year. Things will only get busier from here on. Here are three things your company should be focusing on, or not, right now:
1. Realize that Assisted Acquisition Service Deadlines Have Or Are About to Pass: Are you and your customer seeking an outside acquisition shop to manage your procurement? It’s already too late to bring new business to some centers, like the Interior Business Center. Deadlines for NIH’s NITAAC assisted acquisition shop are fast approaching. If you and your customer can’t get a project together by the middle of the month, look for another route to get your business done.
2. Be an Expert on Simplified Acquisitions and/or IDIQ Contract Use: Your customer’s acquisition shop is overwhelmed. To make sure your great solution gets acquired, you need to provide help and suggestions on how that can happen. Simplified acquisitions, use of IDIQ contracts like NASA’s SEWP and the GSA Schedules, and familiarity with small business set-asides can help you help your customer get the job done fast.
3. Set Dates By Which You Cast Some Business Away and Focus on Other Opportunities: You don’t need to cut your pipeline in half right now, but your company should have a process in place that allows you to focus more and more on what’s “real” and not just “possible”. Some projects that look like winners today may drop off. Let them. Keep your eye on fish that’s already on the line. Follow these simple steps and you can spend October on a beach, not at an industry conference in a stuffy DC hotel.
The Department of Defense awards between 35-39% of its commercial item acquisitions to small businesses. This was among the findings released late last week by the Section 809 DOD Acquisition Reform Panel. One significant finding is that DOD contracting officers do not use much of the simplified acquisition methods already available to them. The report went on in some length about the various ways rules already can make commercial item acquisitions faster and simpler. Panel members speculated, however, that DOD CO’s may not be sure enough of themselves to use available flexibilities and often combine simplified terms with the more formal acquisition rules in FAR 15. The Panel recommended moving simplified acquisition language to FAR 12, the commercial item acquisition chapter. Another recommendation was to eliminate the distinction between personal and non-personal services to make it easier for DOD to acquire the personal services they may need to support critical missions. Here the Panel is essentially giving a nod to reality. Personal services are needed today, and acquired today, so why not make it easier for that to happen? One other recommendation may also be of interest to commercial item contractors: Updating Assignment of Claims processes to reflect current technology and market realities. This, among other things, would make it easier to manage Contractor Teaming Agreements. The entire report is 540 pages long. For those with no meaningful 4th of July plans, the link to the report is here:
https://section809panel.org/wp-content/uploads/2018/06/Sec809Panel_Vol2-Report_June18.pdf
In its well-intentioned quest to be a leader in innovative acquisition, GSA is embarking on a pilot that will, among other things, toss the FAR aside. The agency sites Section 880 of the FY’17 Defense Authorization Act as the supporting statue for this approach to its Commercial Solutions Opening (CSO) project. What, though, does Section 880 say? For starters, it doesn’t Read more
Our national body politic has gotten way out of shape. Whether it’s a diet from the frenzied, social-media driven 24/7 news cycle, or more responsible exercise of our civic responsibilities, the country needs to take steps to become healthier than it is today. July 4th is a great time to take a giant step back from perpetual partisan sniping and remember that there are many things that all Americans have in common. We want to live in good, safe communities. We want our families to flourish. We want the freedom to go about our daily lives without being assaulted, verbally or otherwise. Most of us are also kind to children, the weak, and animals. Benjamin Franklin was once asked what form of government the United States was going to have. He reportedly responded, “A Republic, if you can keep it.” We have a great responsibility to act appropriately in our public and private lives to ensure that we keep what Franklin and his contemporaries gave us. Let’s all remember that as we move forward and do our part to lessen the coarseness of our public discourse.