Sometimes federal procurements don’t go according to the rules. Sometimes its worse, when bribes and kickbacks come into play. That’s what the Justice Department’s Procurement Collusion Strike Force tries to discover and prosecute. Now the strike force is expanding, with four new members. For details, the Federal Drive with Tom Temin spoke with the Dan Glad, the director of the Strike Force.

Interview Transcript: 

Tom Temin And just briefly review the task, the strike force, what it does and what its scope is and where it fits in the hierarchy of oversight here in the government.

Dan Glad Sure. The term collusion strike force, which is a mouthful. So, I’ll call it the PCSF or the strike force. That is the Department of Justice’s coordinated national and inter-agency response to anti-trust crimes and other related fraud schemes that impact government procurement, grant, and program funding at all levels of government, federal, state, and local. And we’ve been around since late 2019. And our mission is really two pronged. One is to enhance deterrence, trying to stop these schemes before they happen. And we do that through education, outreach, and training to both federal agents who investigate these crimes and procurement officers at all levels who are in the position to spot them. And then when deterrence fails and deterrence fails, men are no angels. We look to amplify the detection, investigation, and prosecution of these schemes. I think you asked, Tom, sort of sort of like what we actually do. I’ll tell you what I call our lane. And it’s really we use all the tools in the statutory toolbox, all the parts of the Criminal Code to go after any criminal conduct that distorts, perverts, subverts the competitive procurement process. When the government is going out into the market to buy stuff.

Tom Temin And how do you find out about the fallen angels? Is it mostly whistleblowers?

Dan Glad Whistleblowers are certainly part of the mix. It’s really a combination. We certainly will have whistleblowers who come in and who spot something. The Antitrust Division, which is the part of the Department of Justice I come from, has a long-standing policy of its leniency policy, which is essentially become a cooperator. Tell us about the crimes that you did. And if you do fully cooperate, you’ll get a benefit. The public, we rely on the public to send us tips and leads, and we have a public facing website where members of the public can submit information. Our federal agents and investigators are well positioned to using either confidential sources or just the things they see to refer these matters to us. And then finally, I think I would be remiss if I didn’t mention the people who are really there the procurement officers, the contracting officers, the people in government whose day-to-day job is buying stuff. They are able to spot the indicators, the red flags of these collusive schemes and report them. They often know something’s wrong, even if they can’t put a term on it. And so that’s part of our outreach mission. And since we were founded, we’ve reached more than 31,000 government employees as part of this outreach. That’s 31,000 sets of eyes.

Tom Temin And since 2019, how busy has the strike force been? How many cases have you actually come together and gone after?

Dan Glad We’ve been busy. Since 2019, we’ve opened more than 100 criminal investigations. We have prosecuted to conviction. So, either at trial or through a guilty plea, more than 50 individuals and companies and of our public matter, some cases that are filed. This touches on more than $500 million of government spending. And I will say, I think it’s just the tip of the iceberg.

Tom Temin Well, that was my question. And by the way, we’re speaking with Dan Glad he is director of the Procurement Collusion Strike Force at the Justice Department and the Antitrust Division. I mean, the federal procurement system in the United States is in many ways the gold standard for the world. And most people that participate believe that it’s fundamentally honest. It’s not like India or Russia where bribery and corruption is the norm. Are we still in that place? And these are still exceptions because you say it occurs a lot. Collusion and so forth.

Dan Glad They are exceptions. Federal government procurement is fundamentally sound. The majority of federal government procurement is not a set and attacked by bid rigging, price fixing and fraud schemes. But I think about it in the way it’s the law of large numbers. There’s so much federal procurement that even a fractional loss is substantial. Tom, there’s one study I’m aware of from an international NGO called the organization for Economic Co-operation and Development, or the OECD. And what the OECD tried to do is assess how much money is lost from bid rigging, price fixing and other collusive schemes at the outset from government spending. They looked at all governments around the world, and their assessment is that it’s 20%, that there was a 20% collusion tax imposed by criminal conspiracies on government spending around the world, and the US is probably right there in the middle of that 20% number as a whole. I would say there are parts of the United States that may be higher. Tom, I mentioned before we started talking today that my hometown of Chicago and I worked as the assistant inspector general for the city of Chicago before coming to the Department of Justice. And I can say based on my experience, I think my hometown, though I love it, is likely overperforming that 20% number. There’s another way to think about it. There’s this great quote from a recent 11th Circuit case where the judge opened the opinion by saying, and this is a quote like bears to honey. White collar criminals are drawn to billion-dollar government programs. And that’s true. And I’ll tell you the last way I think about, and I’ve mentioned this because it’s very recent, the GAO, the Government Accountability Office just put out a report where they were trying to estimate they were trying to answer this question. Tom, what is the cost of fraud across the government? And they came up with a numerical figure that’s quite broad, 233 billion to 521 billion every year. And what really stuck with me was the way they contextualized it. They said that if fraud were a government agency, it would be the sixth largest government agency in the United States if there were a U.S. Department of Fraud.

Tom Temin All right. Well, we could probably discuss that philosophically for hours. Let’s get to the operation of the task force. You’ve added new members. Who are they? And what does it mean when a new members added what’s incumbent upon them?

Dan Glad Maybe I took a step back, Tom, and explain sort of our structure. Our strike force includes federal prosecutors. So that’s folks from the Antitrust Division, and we’re now up to 25 US attorney’s offices. So those are the federal prosecutors who sit in cities and districts around the country. We have 12 national law enforcement partners. So, it’s 11 offices of inspector general at the federal level and the FBI. And so, we work together on that two-prong mission set. I’m really happy that we recently welcomed another office of inspector general, the US Department of Commerce, that is now one of our national partners, as well as three new US attorney’s offices to our collective effort. And that’s the District of New Jersey, the District of Alaska, and the Eastern District of Louisiana, which is headquartered in New Orleans. And they will be joining our existing collective effort and also doing environmental scans and being on the lookout and thinking strategically about what’s happening in the commerce world and also in those geographies and on commerce. The U.S. Department of Commerce is embarking on some pretty significant spending. Its second largest spending program in the history of the department is the Bipartisan Infrastructure Law, its number one spot program of all time since its existence is the Chips act. And those are two very recent spending bills.

Tom Temin And by the way, do you also look at state and local level corruption when that happens? Because sometimes the states and the cities don’t have the resources the federal government has.

Dan Glad Absolutely. Some of the core antitrust offenses bid rigging, price fixing, market allocation, criminal monopolization, those are federal offenses wherever they occur at any point in the market, private and public and within the public, which is really where I focus my efforts and my thinking local, state and federal. And we do rely on and work with our partners at that local and state level to uncover, investigate and prosecute crimes that are going after their funding. Relatedly, so much of the funding that comes in to the local and state governments is in whole or in part coming from the federal government. So, the federal government has a very vested interest in making sure that the programs have integrity.

Tom Temin Sure. And just any recent cases that come to mind that kind of stand out for you?

Dan Glad Yeah. Tom, very recently in the month of May, we had a guilty plea in our Idaho fire investigation. There. We indicted two executives with fraud and rigging bids that were submitted to the US Forest service for contracts to provide critical supplies used to fight forest fires. And this was after an investigation that involved court authorized wiretaps. And earlier this month, one of those executives pleaded guilty. Now, what happened here, Thomas? For at least eight years, two executives who were supposed to be competing were not. They conspired to rig bids. They conspired to allocate territories. And this is offering a crucial service that helps U.S. government fight fires in the Rocky Mountain region. And over time, the conspiracy evolved. And they inspired these competitors or anything but competitors. These executives conspired to monopolize the market and they conspired to push other people out. And I’ll say Tom, the evidence here was just really compelling. The executives would text each other talking about how they were going to, quote, squeeze, drown, punch, or lowball their competitors. The wiretap evidence where our federal agents were able to listen in real time due to a court order to the conspirators talking. We were able to hear the executives, and this is all, as alleged in the indictment, conspire about their upcoming bids, about what they would tell the FBI agent. So, the FBI came knocking and how they would hide their conduct. And this really gets to sort of why we do what we do. The U.S. Forest Service relies on a fair bidding process to secure the best deal at the best price for taxpayers. And when people like these executives as allegedly indictment, collude rather than compete, they wronged the public. And more than that time, they are wrong honest competitors who play by the rules. And are doing things fair and square.

Tom Temin Finally, you mentioned that contracting officers, COs 1102s, and people in that function in the federal government are kind of eyes and ears on this. What would you say are the top three signals that a CO should be watching for? That might indicate something bad going on with a contract or an acquisition.

Dan Glad I think the first is any indicators in the contract, in the bid documents, in the contract and documents, any tells that competitors are anything but that two or more bidders are working together. And sometimes that can be the sloppiness that can result. Where you can see a classic example is the same typo. That is, it’s not proof positive, but it’s a lawyer would say it’s probative of a collusive conspiracy. The other thing I always tell contracting officers, and it sort of goes back to my thought that humans are pattern recognition machines. We can recognize patterns even if we can’t articulate it. If a contracting officer has this sense that they know who’s going to win before they, in the old days, open the envelopes with the bid. But today sort of go into the procurement platform to open the bids. I would ask a contracting officer sort of pause. And as they said in Star Wars, search your feelings, figure out what’s going on, why you have this inclination that someone’s going to win. Again, not proof positive, but these schemes are iterative. They are pattern. They happen over time. There’s no such thing Tom as a bid rigging Crime of passion. You have. Over time, when you are procurement professional, you’re invested, and you will have been able to spot that pattern. And the third thing is sort of look in the pricing, look at the information you have. If pricing is all going up lockstep that’s a red flag not proof positive but it’s a red flag. There may be an innocent explanation for it. If pricing is very, very close or it’s off by round numbers or round percentages, that can be an indicator of a collusive scheme bid rigging, price fixing, or some other kind of fraud.

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Agencies, once again, set new records almost across the board for contracting with small businesses in fiscal 2023. New data from the Small Business Administration shows agencies awarded an all-time high of 28.4% of all eligible federal contract dollars to small businesses.

At the same time, SBA’s new small business scorecard data shows agencies met or surpassed governmentwide goals in three of five socio-economic category, including service disabled veteran-owned small businesses.

In all, agencies awarded $178.6 billion to small businesses last year, which is an increase of $15.7 billion from 2022.  The governmentwide small business contracting goal is 23%.  House Small Business Committee lawmakers recently passed a bill to increase that goal to 25%.

FY23 Prime Contracting by Dollars and Percentages for All Categories*:

• In accordance with federal law, SBA provided double credit for prime contract awards in disaster areas that were awarded as a local area set aside. SBA also included in the calculation of government-wide achievements Department of Energy first-tier subcontracts required to be included by section 318 of the Consolidated Appropriations Act of 2014 (“CAA”), Public Law 113-76.

Overall, SBA says 10 agencies received “A+” grades and two others received “A” grades on the scorecard, including the SBA, the departments of Agriculture Housing and Urban Development, Interior, Homeland Security and Commerce as well as the National Science Foundation, the General Services Administration, the Nuclear Regulatory Commission and the Office of Personnel Management.

The White House and SBA recognized the small business contracting accomplishments during a roundtable today as well as during National Small Business Week, which kicked off yesterday.

As part of the 2023 scorecard, SBA also released contract data broken down by business owner race and ethnicity, which shows that businesses owned by historically underrepresented groups earned more through federal contracts across every category. Agencies awarded $76.2 billion to small disadvantaged businesses, the most ever, surpassing the Biden administration’s goal of 12%. The White House set a 15% goal for 2025.

“This represents the third consecutive year of record-breaking awards to SDBs under President Biden, and puts the administration on track to reach the President’s goal of increasing federal contracting dollars to SDBs by 50% by 2025,” the White House said in a fact sheet released today.

For example, African-American owned businesses received $10.2 billion in federal contracts in 2023, $800 million more than in 2022. Meanwhile, Hispanic-owned businesses saw their overall contract dollars increase by $943 million to $10.9 billion last year.

FY23 Federal Contracting Dollars to Minority-Owned Small Businesses:

In addition to beating the SDB goal, the SBA says agencies also exceeded the service-disabled veteran-owned small business goal of 3%. Agencies awarded $31.9 billion, or 5.07% of all contracts to these firms.

This also is first time agencies came close to meeting the goal for women-owned small business awards in several years, missing out by less than 1%, while still awarding $30.9 billion to these companies.

Along with prime contracts, agencies exceeded their goals in making sure small businesses received subcontracts. SBA says 33.34% of all subcontract dollars went to small companies, more than 2% above the goal for a total of $86.4 billion.

Unlike with prime contracts, agencies missed all socioeconomic goals under subcontracting except for women-owned small businesses. The women-owned small business goal was 5% and agencies achieved 5.65%, while missing out on the SDB, HUBZone and service-disabled veteran-owned small business goals.

This latest scorecard comes when House and Senate lawmakers are pushing SBA to hold agencies more accountable for small business contracting. Sen. Joni Ernst (R-Iowa), ranking member of the Small Business and Entrepreneurship Committee, introduced the Accountability and Clarity in Contracts to Engage Small Suppliers and Small Businesses (ACCESS) Act last September to revamp the goaling structure.

House Small Business Committee lawmakers also passed several bills earlier this month to address long-standing concerns like making sure agencies use plain language when writing contracts and bring more transparency to decisions when agencies cancel small business contracts.

The post Agencies set records for small business contracting in 2023 first appeared on Federal News Network.

The General Services Administration is putting the final touches on its solicitation for the Alliant 3 IT services contract.

But one of the sections that GSA is already finished with is a new approach to attracting small businesses with new or emerging technology capabilities.

Large businesses can get started today on meeting the requirements of GSA’s small business emerging technology solutions engagement requirements under Alliant 3 contract.

Paul Bowen, the director of the center for GWAC programs at GSA, said this evaluation factor is among the first of its kind.

“There’s an opportunity for an ‘other than small business’ offeror to engage with small businesses that have eligible emerging technology solutions in any of these 11 areas. So if I’m an other than small business company, I have the opportunity to go out and interact with up to five small businesses that have emerging technology solutions, meet with them, have them sign a form that shows that we met, we had an engagement and that we spoke,” Bowen said at an event sponsored by ACT-IAC on Friday. “The small business has to provide the proof that they have the eligible product, and then when the other than small business submits it to GSA. The other than small business would receive 200 points for each of the five engagements up to a total maximum of 1,000 points.”

As part of the draft solicitation for Alliant 3 issued last December, GSA detailed this new approach to hold large businesses accountable for learning about small businesses in specific emerging technology areas. The 11 areas included such as big data, cloud, cyber, AI, zero trust and quantum computing.

GSA highlights 11 emerging tech areas

What the small business emerging technology solutions engagement requires is for large businesses to meet with at least five small businesses who work in one of these 11 areas. The 11 emerging tech areas came from work GSA’s IT Category office has been and continues to do.

Bowen said GSA isn’t being prescriptive about how the engagements work or what may or may not come from them.

“GSA does not dictate how these meetings are set up, how long they last, the terms of them. It’s entirely for you to all figure out how you want to do it and to come to terms with each other, whether it’s a phone call, whether it’s a meeting, whether it’s a demonstration, however you work it out, you work it out,” he said. “There’s no expectation that you will have done business in the past. Nor is does it create an obligation in GSA’s eyes that you’ll do business together in the future. It’s a way to match make.”

GSA, however, put some parameters on the size of the emerging small businesses. The firm has to have done at least $100,000 worth of business or being a part of the Small Business Innovation Research or Small Business Technology Transfer (SBIR/STTR) programs.

Under the terms of the program, the large business may only get credit for meeting with a different small business for all five engagements and can’t meet with small businesses in any of the 11 categories like cyber or AI more than twice. Bowen said that means if large company X meets with two different AI companies, then they have to pick three other emerging technology areas like cloud or health IT for their other meetings.

Matchmaking made easier

Small firms bidding on Alliant 3 do not have to participate in this part of the evaluation. GSA says they would receive the 1,000 points automatically.

Bowen said GSA’s decision to take this approach made sense for several reasons.

First, it just made sense to make small business matchmaking part of the evaluation factor just made sense.

“We know that small businesses have really been leaders in emerging technology, which is such a focus for everyone, including the government. For us to have an evaluated factor where other than small business offers on Alliant 3 have a scored element where they can go out and meet with small businesses with emerging technology solutions is a win-win for everyone,” Bowen said. “It’s a win-win for the small businesses with the emerging technology because they have the ability to go meet with these companies where previously may have been difficult to get in the door. It’s a win for the other than small business offers because they get to learn about these technologies. They demonstrate to the government that they have the ability to go out and find small businesses with emerging technology because so much of the emerging technology is being done to almost the garage level and above at this point.”

Bowen said this approach also gives the small businesses some leverage with the large firms in terms of getting meetings and explaining their technologies and value.

In addition to this 1,000 point evaluation factor, Bowen said GSA also will hold vendors accountable for meeting their subcontracting goals as part of the contract.

GSA expects to issue the final solicitation for Alliant 3 toward the end of May or early June.

One big change to the Alliant 3 is the number of awards GSA is expecting to make. Bowen said GSA is targeting about 76 awards, which is up from the 60 awards it made under Alliant 2 back in 2018.

One reason GSA is looking to make a larger number of awards is the number of contractors who ended up leaving Alliant 2. GSA started with 60 awards and has lost 22 over the last six years. Of those 22, 11 were lost to mergers and acquisitions and another 11 to the companies “volunteered” to leave the contract as they were not meeting specific bidding and winning requirements.

There now are 38 vendors under Alliant 2 and GSA expects the larger number of awardees to provide better and more competition.

Alliant 2 remains a popular contract among agencies, adding a lot of focus and excitement on Alliant 3.

GSA data shows agencies obligated more than $8.6 billion across 117 task orders in 2022. Since GSA awarded Alliant 2 in 2018, agencies have obligated more than $26 billion.

The popularity of Alliant 2 caused GSA in August 2022 to increase the ceiling of Alliant 2 to $75 billion from $50 billion because it saw the increasing spending trends.

Over the last four or so years, Alliant 2 has been a go-to contract for many of the major and high dollar programs agencies have pursued. The average task order under Alliant 2 is around $120 million.

Industry and GSA expects Alliant 3 will be just as popular with spending continuing to increase.

The post GSA’s new approach to small business matchmaking first appeared on Federal News Network.

• A major contractor for the Veterans Affairs Department is getting acquired. Cognosante, a provider of digital transformation and cloud modernization services, will merge into Accenture Federal Services. Cognosante won more than $300 million in federal prime contracts the last two years, with its largest customers being the VA and the Centers for Medicare and Medicaid Services. Cognosante holds spots on several governmentwide contracts including CIO-SP3, OASIS and Alliant 2. Accenture Federal Services did not disclose the terms of the deal.
  (Accenture Federal Services to buy IT services firm - Businesswire)
• The Energy Department is making it easier for employees to test out artificial intelligence tools, with its new AI discovery zone, which aims to let its employees explore large language models and generative artificial intelligence tools in a safe environment. The sandbox gives DOE AI researchers and developers a platform to experiment with Google and other generative AI tools using public data. One prototype that DOE is developing would make it easier for grantees to search for and determine if they are eligible for specific agency grant opportunities. The Energy Department is also running an intra-agency working group to develop best practices and a reference guide for safely using GenAI across the department.
  (Energy’s giving employee safe space to discover AI - ATARC)
• U.S. Cyber Command is growing its acquisition program. CYBERCOM is adding 50 billets to its acquisition workforce this year. The command started with just 10 billets in 2017, but now has slowly built up its acquisition programs as Congress has granted it new buying authorities. The command has more responsibility to procure the cyber weapons and services relied upon by its Cyber Mission Force. CYBERCOM is training its growing workforce on non-traditional acquisition tools, such as DoD’s software acquisition pathway.
  (CYBERCOM embraces the non-traditional as acquisition program grows - Federal News Network )
• Senate plans to find a permanent home for pandemic-fraud fighting tools are getting support in the House. House Oversight and Accountability Committee Ranking Member Jamie Raskin (D-Md.) introduced the Government Spending Oversight Committee Act. The bill would preserve data analytics tools used by the Pandemic Response Accountability Committee (PRAC) and would redeploy them to uncover more fraud in federal spending. Those tools have helped agency watchdogs uncover nearly $2 billion in pandemic-era fraud. But those tools are currently scheduled to go away when the PRAC disbands in September 2025. This is the House version of a bill that passed out of the Senate Homeland Security and Governmental Affairs Committee last week.
  (White House-backed bill to preserve pandemic fraud analytics tools introduced in House - Federal News Network)
• Lawmakers are pushing for more access to specialty services in the military’s health care system. Right now, appointments for specialties like physical therapy, nutrition and optometry can take weeks. A special House panel on quality of life in the military said DoD needs to make those services available without a referral. Those recommendations are among dozens of others the committee has teed up for inclusion in the 2025 Defense authorization bill.
  (Lawmakers push for military health care expansion - House Armed Services Committee)
• There is a new official in charge of building out technologies that underpin the background investigation system. The Defense Counterintelligence and Security Agency has named Edward Lane as program executive officer. He will oversee key programs, including the National Background Investigation Services. That effort aims to modernize and integrate background investigation technologies into one unified system. Lane previously served as deputy senior acquisition executive at the Defense Intelligence Agency.
  (DCSA names next program executive officer - DCSA)
• The IRS hit its goal for the number of taxpayers who used a new option to file their taxes online. And they filed for free. Provided this year by the IRS, more than 100,000 taxpayers used the Direct File platform to file their federal tax returns, meeting the agency’s target for users. About 50,000 of those taxpayers filed their returns during the final week of the filling season. The IRS invited taxpayers in 12 states to test out the Direct File pilot program this year. The agency is reviewing user feedback to see if it should scale up the program next year.
  ( - Treasury Department)
• Congress wants to expand a pilot program to provide fellowship opportunities for military spouses. The program, facilitated through the Chamber of Commerce Foundation’s Hiring Our Hero program, has proved to be successful since its inception in 2022, so Congress wants to make it a permanent program. In 2023, over 400 fellows participated in the program, with nearly all of them landing permanent jobs with annual salaries of $65,000 and above. Lawmakers said their recommendation to make the program permanent will be included in the 2025 defense policy bill.
  (Lawmakers want to expand the military spouse career accelerator program - House Armed Services Committee)

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The Air Force is out with a new multiple award solicitation to modernize all of its base network infrastructure.

The request for proposals uses the phrase, “enterprise IT-as-a-service” only a handful of times, but for all intent and purposes, this potentially 10-year contract with a $12.5 billion ceiling is considered Wave 2.

The new RFP calls for a group of large and small businesses to “modernize, operate and maintain the network infrastructure on all Department of the Air Force locations, to include Guard and Reserve bases.”

The Air Force is planning to award at least five contracts to 8(a) firms as well as a minimum of three awards to HUBZone companies, women-owned small businesses, service-disabled veteran-owned small business firms and other small businesses not in a socioeconomic program.

“This effort takes lessons learned from the EITaaS risk reduction effort network-as-a-service effort as well as lessons learned from existing base IT infrastructure modernization efforts to modernize the future base area network (BAN) offering at Air Force bases worldwide,” the RFP states. “This effort intends to modernize the Non-Secure Internet Protocol Router (NIPR) and Secure Internet Protocol Router (SIPR) BAN through an as-a-service model utilizing contractor provided networking services.”

The Air Force says its goal through the BIM vehicle is to obtain standardized, innovative and agile IT services, increase integration through a modern streamlined network and to be an investment for future mission sets.

Air Force to reduce data centers

Winston Beauchamp, the deputy chief information officer at the Air Force, said the goal is to award the multiple award contract later this spring with the first set of task orders going out before the end of the fiscal year.

Beauchamp said the Wave 2 EITaaS RFP comes as the Wave 1 effort is picking up steam.

“They started by essentially absorbing the bases that were part of our risk reduction experiment originally, that preceded the acquisition, and they are right now delivering common central services that will be applicable to all bases,” Beauchamp said in an interview with Federal News Network after speaking at the AFCEA NOVA Space IT day. “We’re talking about things like a centralized helpdesk automation so that folks can do certain things on their own, like resetting passwords, and answering tier zero help desk type questions. Then also to come there’s field services. The option for folks to use our contract to put people in the field to support them at the bases of all that for centralized security and help desk services.”

The Air Force is using the base infrastructure modernization contract as a key piece to its centralization strategy. Beauchamp said not every IT service needs to be an enterprise service, but there are a wide variety of opportunities for the Air Force to improve how it delivers technology to its users.

For example, across the 185 Air Force and Space Force bases there are about 1,000 data centers running.

Beauchamp said the CIO’s office is making a big push to move applications to the cloud, where it makes sense.

“We fully expect that more and more applications will be moving into our cloud architecture. That’s called CloudOne today, and that contract is up for renewal. It will be re competed, and it will be calling it CloudOne Next, but the intent is that it will be just the next evolution of the CloudOne program,” he said. “The interface between that and the Joint Warfighting Cloud Capability (JWCC) our intent to leverage that contract to the maximum extent possible by buying cloud services capacity through JWCC, and then managing it under the CloudOne contract. The expectation is that we would continue to acquire cloud through JWCC, where it’s cost effective to do so in bulk and then we would provision it with security services that DevSecOps and the other layers of services that we’ve built up over the years on the under the CloudOne contract.”

Three cloud contracts in the works

The Air Force released its request for information for CloudOne Next in September and just in March, it offered more details on its acquisition strategy.

The Air Force expects to release three solicitations for CloudOne Next in the third quarter of 2024 and make the award in the fourth quarter of this year. It will be three single-award blanket purchase agreements on top of the schedules program run by the General Services Administration.

The three BPAs will focus on:

• Cloud service provider (CSP) reseller and software management
• Architecture and common shared services
• Enterprise application modernization and migration

Beauchamp said the Air Force is evolving from siloes of excellence where every system built its own technology stack to a series of enterprise capabilities where the burden to sustain, modernize and secure is shared.

“We really have is an opportunity to look at the degree to which there may be commonality between those approaches, either in factor or in potential, and where we can either use collective buying strategies to reduce the overall cost collective across the Air Force and collectively across DOD, to get the best possible deal through economies of scale,” he said. “If there’s an architectural approach that perhaps could leverage an existing enterprise service, we want to make sure that we have the ability to see them and to make those recommendations to really free up the time and resources so that those dollars can be applied towards more effective mission capability.”

This approach to IT portfolio management is one of the six lines of effort Air Force CIO Venice Goodwine outlined in her strategy.

Other lines of effort include the acceleration of cloud adoption, the future of cybersecurity, including zero trust, workforce development and training, software management and data and artificial intelligence.

Beauchamp said IT portfolio management, or line of effort 4, is one of the most exciting opportunities for the Air Force. He said IT portfolio management can create leverage across the entire department that can result in both savings and money redirected toward mission needs.

“Overall, I think that each of the sub objectives within line of effort four are going to contribute in some way in that direction. Everything from implementing a capital planning and investment control (CPIC) approach within the Department of Air Force, which we are piloting this year, to improving our monitoring of the user’s experience, which really enables us to target our modernization efforts on those areas where folks are suffering the most will allow us to make better use of the resources that we have for free enterprise IT,” he said. “One of the things we’re going to have to do is really reexamine how we’re implementing CPIC. When I say the pilot, what we’ve done is we’ve selected a major command and a couple of functional areas, where we’re going to put a more rigorous capability in place to really meet not just the letter of the law, but the spirit as well, and apply the data to actually make business decisions. That’s the key. If you if you’re going to go to the trouble of collecting all this data about your programs, you might as well use that data for informing your decision making.”

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GSA is expanding the number of providers from three to eight, including six new ones.

Along with current platform providers Amazon Business and Fisher Scientific, GSA awarded spots on the next generation Commercial Platform Initiative (CPI) contract to:

• e-Procurement Services
• Grainger
• Noble Supply & Logistics
• Pacific Ink
• Social Glass
• Staples

Four of the awardees, ePS, Noble Supply, Pacific Ink and Social Glass, are small businesses, opening the door for agencies to obtain small business credit for these small dollar buys.

“This is about meeting our customers where they are with a modernized user experience and streamlined process for government purchase cardholders,” said Tom Howder, the acting Federal Acquisition Service commissioner, in a release.

GSA created the CPI program under a proof-of-concept moniker with awards to Amazon, Fischer and Overstock Government in 2020 under direction from Congress with a goal of capturing data on and managing products under the micro purchase threshold of $10,000. Initially, GSA thought the market was about $6 billion, but came down in the last few years to the potential market being about $500 million.

Overstock Government decided not to bid on the next generation platform, sources say.

Lawmakers detailed its desire for GSA to pilot online commercial platforms in Section 846 of the 2018 Defense Authorization bill. The House Armed Services Committee’s initial goal was to make federal procurement less complex and more competitive through the use of commercial platforms.

“GSA’s announcement of eight contracts awards for the commercial platform initiative represents the passing of a significant milepost on its journey to bring enhanced electronic commerce to agencies,” said Roger Waldron, president of the Coalition for Government Procurement, in an email to Federal News Network. “Collectively, these contracts represent a streamlined channel through which agencies can acquire commercial off the shelf products quickly. They also put competitive pressure on the Schedules program to improve its administrative efficiency, which is a positive result that will help buyers and sellers in the market.”

The awards come at more and more agencies are using the initial three platforms, though data shows Amazon Business received the vast majority of the orders, accounting for 96% of all orders in fiscal 2022, according to an August 2023 report from the Government Accountability Office.

GSA says for 2023, 34 agencies spent $80 million, which is double the amount of money spent in 2022.

GSA also says total orders also increased to 305,000 from 105,000 in 2022, and 52% of all users were repeat buyers and agencies spent on average between $250-$350.

“This is a pivotal turning point in the Commercial Platforms Program as we expand the number of platforms available, including a number of small business awardees,” said Keil Todd, the Commercial Platforms program manager, in the release. “We’re excited to move out on the next-generation of this program to further our commitment to agencies in helping them get the products they need to support their missions.”

With the additional companies GSA is adding, agencies have access to buy from well-known diverse companies like Amazon Business, Fischer Scientific, Staples and Grainger that provide a large variety of products, but from the four small companies.

Noble Supply, for instance, provides the Defense Department with access to products from 13,000 companies.  Pacific Ink offers office supplies and Social Glass provides access to small purchases across 50,000 products. And ePS  filed a protest of the solicitation in December only to gain corrective action and win an award.  ePS is a platform providing access to small business suppliers.

“We are looking forward to assisting GSA in meeting the goals of the Commercial Platform program. This award allows us to bring other federal agencies the benefits that federal buyers are currently experiencing within the e-Procurement Services (ePS)  Army and Air Force eMarketplace programs,” said David Saroli, CEO of e-Procurement Services (ePS), in an email to Federal News Network. “Being part of the Commercial Platform program will also help increase the growth our small business suppliers are currently experiencing through the Army and Air Force ePS e-marketplaces.”

The journey to this award, and it’s unclear if GSA has crossed the finish line given several unknown factors like how many bidders there were and if any that were unsuccessful would file a protest, was not an easy one. GSA took heat for initially overlooking, or ignoring, the requirement to comply with the Javits-Wagner-O’Day (JWOD) Act. The 1938 law mandates the AbilityOne Commission publish a procurement list that identifies commodities and services that the commission has determined are suitable to be furnished to the government by companies who employ people with disabilities. Agencies must buy these specific products and services unless there are specific circumstances that require exceptions.

GSA ended up fixing the solicitation to satisfy the protestors’ concerns.

The post GSA’s commercial platforms program to grow by five providers first appeared on Federal News Network.

An employee at the Federal Acquisition Service in the General Services Administration suggested using modern technology like 3D scanners to improve the maps of federal buildings to benefit emergency responders and others.

And two federal employees at the departments of Veterans Affairs and Commerce’s Census Bureau submitted an idea to translate ethical artificial intelligence principles into technical steps by developing processes to assess AI at every level, from inception to development, production and continuous performance evaluation.

These are just three of the 16 ideas from 10 agencies that GSA’s 10x program is considering for possible funding in 2024.

“Our fiscal 2024 investment priorities centered on ideas for reimagining public engagement and promoting equity in delivery. We also emphasized ‘Moonshot’ ideas: the biggest, boldest and most ambitious ideas to transform digital public services,” GSA wrote about 10x in a new blog post. “This round, ideas for artificial intelligence projects emerged as a standout category. Nearly one fifth of all the submissions we received were related to AI.”

GSA launched the 10x program in 2015, and it is now part of the Technology Transformation Service, as a venture studio where they ask federal employees to send ideas and then makes small investments with the goal of improving federal digital experiences.

GSA 10x to begin analysis

For the 2024 funding opportunity, 10x received almost 200 ideas from more than a dozen agencies. Along with AI, other topics included accessibility technology, public-to-agency communications and improving data sharing.

10x now will move these 16 projects into phase one of the program where cross-functional teams of technologists will try to answer the simple question, “Is there a there there?”

“They investigate the problem, get a sense of how and if this idea could impact the public, and explore whether a technology solution is possible,” GSA wrote. “We use the phase one findings to guide our investment decisions as we decide whether or not to move a project into subsequent phases.”

In a phase two, the 10x team analyzes the idea to decide if it’s ultimately a technology problem or not. If it’s more of a people, policy or funding challenge, 10x will not invest more resources in developing a product or service.

In phase three, the 10x team makes sure the solution integrates with the agency partner’s existing priorities and technology capabilities. The team is reviewing workflow processes and how the agency can continue to sustain and support the technology. Most 10x projects end after Phase 3, when the product is handed off to its agency product owner.

Then in phase four, 10x and the agency sponsor look to scale the technology to support different use cases across agencies and programs that drive the biggest impact with an ultimate goal of transforming digital services for the public.

10x says most ideas never make it to phase 2. For instance in 2022, of the 25 ideas that made it to phase one, only seven received funding for phase two. Additionally, 10x says fewer ideas actually make it to phase three and four where the team scales the solution to the public.

The notify.gov project is an example of a 10x funded program that made it to phase four.

Another example is the site scanning platform that offers real-time intelligence to help agencies improve website performance and compliance with government mandates by providing web managers with a customizable, automated scanning service.

The post GSA’s 10x to take deeper look at 16 ideas submitted by feds first appeared on Federal News Network.

When it comes to blue collar wages, a different standard seems to apply to federal agencies and to contractors. Two standards appear to apply when it comes to Trade Agreement Act Compliance. What’s going on? For on view, the Federal Drive with Tom Temin spoke with federal sales and marketing consultant Larry Allen.

Interview Transcript: 

Tom Temin You are pointing to a Gao report and some other activities of the government which show that sometimes they don’t follow the rules agencies when paying things directly, that they expect contractors to follow. Tell us more.

Larry Allen A time that’s right. I think the bottom line is contractors need to always remember exactly where it is they stand when they’re doing government business, and that places at the bottom of the ladder. Even if you’ve got people working side by side in a government agency. The only real difference being the type of bad contractors need to understand that a different set of rules apply to them. That’s come out quite clearly recently. As you alluded to, the Government Accountability Office came out with a report recently saying 75% of federal agencies pay their hourly wage workers incorrectly, while some agencies pay more than the prevailing wage, a number of the pay less. And that was kind of the end of the GAO report. By contrast, if a contractor had been found to not be paying prevailing wage rates either under the Services Contract Act or in construction via Davis-bacon, they would have been really taken to the compliance woodshed. And that’s just a very much a double standard. Contractors need to be aware of that issue, and contractors can spend a lot of money, hundreds of thousands of dollars for larger companies every year, ensuring that they stay in compliance with labor and wage rate requirements. It’s a whole thriving legal practice in and around the Beltway, too. Then the second part of it was the trade agreements that we read recently about the General Services Administration CIO getting taken to the congressional woodshed for his agency’s failure to do all the due diligence it should have done around the Trade Agreements Act. By and while getting taken to the congressional woodshed is never pleasant. It pales in comparison to the sometimes years long, 7 or 8 figure defenses that contractors have to put up when they are accused of Trade agreements act wrongdoing. That’s the second issue, and I’m just using these two issues to highlight the fact that contractors, again, they need to understand where they are. They can be scapegoated. They can have fingers pointed at them, even when things may not entirely be their fault, it’s easier to blame the contractor. So, you just have to be smart about how you’re approaching government business. Understand that there’s sometimes can be two standards. As I often told my teenage children, life isn’t fair.

Tom Temin That’s right.

Larry Allen I think you just have to remember that you.

Tom Temin Can’t win by saying to the government, well, you only paid those people less than the federal minimum wage or less than the Missouri or Michigan or whatever. It is minimum wage. But that’s not going to help you in federal government.

Larry Allen So a little bit like the parents of the teenagers in this case, Tom, it’s definitely do as I say, not as I do.

Tom Temin Right. In the Trade Agreement Act. By the way, the GSA incident that you mentioned concerns the acquisition of Chinese made conference room cameras, where presumably China has the potential to listen in on what’s going on in federal conference rooms because of that little cute camera sitting in the middle of the table.

Larry Allen If the Chinese are having trouble staying up at night, I recommend that they listen in on a lot of GSA conference calls.

Tom Temin We’re speaking with Larry Allen. He’s president of Allen Federal Business Partners. And let’s talk about the appropriations bills that are now law. And we are into the second half, almost of the of the federal fiscal year. And there’s actually appropriations for 2024. The numbers are good for contractors.

Larry Allen Tom. They are good for contractors, particularly if you’re selling to the Department of Defense or the Department of Homeland Security. Both of those agencies received funding increases over what the president had originally requested in his FY 24 budget request, particularly in the Department of Defense. You’re going to see things for all kinds of weapons programs, for research to maintain the U.S. technological edge across the board. In DHS, a lot of that funding is going to go to the southern border. And while a lot of it’s going to go to higher personnel, it’s also going to go to technology that the personnel can use in the conduct of their mission. So those are two good opportunities. And really what we’re talking about here is, you know, essentially by the time each individual office gets its numbers, spending number, we’re talking about five months left in the procurement. Cycle for this year. So just to modify a phrase, it’s very much, ladies and gentlemen, start your engines.

Tom Temin Yeah that’s right, because it takes a few weeks for the moneys to get deposited in the accounts.

Larry Allen What happens now is the Office of Management and Budget takes all the appropriated money. They pass it out to a certain degree for each agency. Give that back to the finance people in each agency, and then the agency further subdivides it to get into individual spending accounts. It’s a process that usually takes 4 to 6 weeks, depending on the agency.

Tom Temin Yeah. So that puts us into or puts federal contractors and buyers into what, May before they can actually.

Larry Allen That’s right. So, if you were planning on taking that spring vacation, think again. Bloomberg government recently reported that the sustained delay in implementing appropriations resulted in a 40% decline in government business. That’s a lot of business that’s going to have to be made up between now and September 30th.

Tom Temin What’s your best advice for contractors? I mean, they’ve got to somehow get the government to focus on spending and focus on letting these contracts, because the money is not multi-year money. So, it’s either spend it or lose it for a lot of these dollars in the in the 5 or 4 and a half months, it’ll remain when the government can actually do something.

Larry Allen Indeed. So, Tom, and I think one of the main things that contractors can do now is make sure you’re ready with a fast and reliable acquisition method that you can recommend to your government buyer. While some government agencies do have preferred acquisition methods, others are going to be looking for ways to get money obligated. That’s the key word. Get that money obligated by midnight, September 30th. And if you’re a contractor and you’ve got a couple of good fast options, whether it’s one of the many government wide acquisition contracts like GSA is a line three, or whether it’s, socioeconomic status like AA sole source, whatever it is that you’ve got that you can recommend as a fast and efficient way to get that agency to commit the money, you’re going to be that much of a better partner.

Tom Temin It also points to the fact of the need for being on the right contract vehicles for task orders because that’s the most efficient route from the government standpoint. And so, it really underscores the importance that you got to be able to have vehicles.

Larry Allen Well, right. And Bloomberg government recently came out with a report on that as well, talking about the use of best-in-class contracts. And while a lot of these are in the information technology world, Tom, there are also plenty of big spending that happens in the professional service, logistics, transportation worlds as well. So, agencies, more and more particularly civilian agencies are looking to these best in class, short name big contracts to do acquisitions. And what you find is that successful government contractors have 2 or 3, sometimes more, of these vehicles that make it easier for agencies to do business with them. And while there could be some grumbling among contractors about which type of contract gets a best-in-class designation, the fact is that agencies often view that as a symbol, that it’s a gold star type of program, that you can use, that nobody’s going to second guess you about.

Tom Temin All right. So, some work to do, basically.

Larry Allen Lots of work to do in a very short period of time to do it in.

The post Contractors wonder which of two procurement systems applies to them first appeared on Federal News Network.

The Defense Department uses the metric known as procurement administrative lead time, or PALT, to measure the time between the date an initial solicitation for a contract goes out and the date a contract is awarded.

A government watchdog agency said that while there have been improvements in contracting processes since DoD began collecting data to measure PALT in 2018, the award lead times vary depending on total contract value, contracting approach, contract type, extent of competition and the type of product or service procured.

For example, the award time on orders valued over $50 million increased by 70 days in the last four years.

The Government Accountability Office found that the median DoD-wide award lead times decreased by more than 20%, from 41 days in 2019 to 32 days in 2022.

DoD-wide median lead time by contracting approach:

• Definitive contracts: 97 days
• Indefinite delivery contracts: 179 days
• Orders: 21 days 

Median order award times are generally shorter across the service branches, while definitive and indefinite delivery contracts take significantly longer to award. For example, the Navy takes 132 days to award a definitive contract and 185 days to award indefinite delivery contracts.

In some instances, it takes under a day to place an order since those can be fulfilled through an indefinite delivery contract awarded to one vendor where all terms and conditions are already established.

For example, the Defense Logistics agency awards many orders for commercial goods, services and  supply items on existing indefinite delivery contracts, often with the help of automation, which allows the agency to process the awards in under one day.

“Over 85% of all definitive contracts awarded and over 90% of all orders issued by DoD from fiscal years 2019 through 2022 were below $10 million in value and had shorter median PALT timeframes. PALT values, both DoD-wide and within selected components, were generally longer for the award of definitive contracts and orders with larger total contract values,” the report stated.

The Army and Navy contracting processes decreased by 13% and 12%, respectively, while the median award times remained the same for the Air Force and the Defense Logistics Agency.

Additionally, the award times decreased for competed contracts but remained the same for sole-source contracts or those awarded through other non-competitive methods.

For example, the Army takes 247 days to award a contract within the research and development category, but it takes 102 days for the Navy and 131 days for the Air Force to award a contract within the research and development category.

For comparison, the Army takes 69 days to award a contract within the electronic and communication equipment category, while it takes 55 days for the Navy and 42 days for the Air Force to award a contract within the same category.

Generally, the service branches have adopted strategies to monitor award times. 

The Naval Sea Systems Command categorizes its contract awards by competed and non-competed contracts and then sets its goals. 

For example, the command’s goal for sole source procurements is not to exceed 210 days, while competitive procurements cannot to exceed 240 days.

The Army categorizes contract awards into four groups and assigns award-time estimate to each group by dollar value and contracting approach.

For example, for $100 million to $250 million contracts, the award times range from 80 days for orders placed on an existing indefinite delivery contract awarded to one vendor to 270 days for awards of new contracts.

But DoD doesn’t have department-wide visibility and understanding of the award times. And the DoD’s PALT tracker has shown to be of  limited use because of its incomplete data.

Additionally, the military services don’t find the PALT tracker useful and “reported that it is burdensome and duplicative of other systems they use.”

“Given these different perspectives, DoD would benefit from engaging with the components to determine if the PALT Tracker is needed to enhance DoD’s visibility into PALT changes for higher-dollar value contracts,” the report stated.

The post DoD award lead times increased for higher value contracts first appeared on Federal News Network.

• The Defense Department will receive $18.7 billion for military construction and family housing initiatives for fiscal 2024. The six-bill spending package passed by the House yesterday, includes funding for 300 military construction and housing projects. The 2024 Military Construction-VA bill provides $662 million to build over a dozen barracks, with roughly $320 million going toward revitalizing five privatized housing projects. The legislation also includes $2.5 billion for shipyard infrastructure optimization plan projects.
  (Defense Department will receive $18.7 billion for military construction projects - Senate Appropriations Committee)
• The Environmental Protection Agency (EPA), the FBI and the Bureau of Tobacco, Alcohol, Firearms and Explosives (ATF) are among the agencies that will likely have to deal with less money for the rest of the fiscal year. In the House version of the minibus package of appropriations bills passed yesterday, the EPA is getting 10% less funding than last year, while the ATF will be down 7%. The FBI is facing a 6% reduction. The Senate is expected to take up the package of bills before the continuing resolution expires on Friday night.
  (House passes $460 billion package of spending bills. Senate expected to act before shutdown deadline - Federal News Network)
• Two agencies will be looking for new technology leaders in the coming months. The Education Department is in need of a new chief information officer. The Homeland Security Department will have to fill its chief information security officer role this spring. Federal News Network has confirmed Luis Lopez, the Education Department CIO since December 2022, is leaving on March 22. He will take a job in the private sector. Meanwhile, DHS CISO Ken Bible is retiring after 39 years of federal service. His last day is March 29. Bible has been with DHS since January 2021, coming over from the Marine Corps.
  (Education, DHS among agencies seeking new technology leaders - Federal News Network)
• Pretty soon, there may be lots more apprenticeship opportunities in government. An executive order President Biden signed Wednesday tells federal agencies to take better advantage of the Labor Department's registered apprenticeship program. Agencies have spent years trying to shift away from college degree requirements for federal jobs. Now the Biden administration said offering more federal apprenticeships should get those skills-based hiring efforts further off the ground. The order encourages agencies to eventually turn apprentices into full-time federal employees. As another new requirement from the order, agencies will now create labor-management forums, if they do not already have them. The forums are meant to help federal unions and agency managers address employee concerns more easily and before they escalate.
  (White House presses agencies to use apprenticeships for skills-based hiring - Federal News Network)
• The Department of Veterans Affairs said it plans to hire-and-market jobs to military spouses. VA is leading a public-private partnership to adopt employment policies, such as telework and job transferability, that benefit military families. The VA said it is a leading employer of military spouses and offers jobs that travel with them, whenever their spouse has a change of station. The VA also allows military spouses to telework overseas and to hold federal jobs stationed in the US. The department is rolling out these efforts as part of an executive order President Joe Biden signed last summer to address a more than 20% unemployment rate among military spouses.
  (VA makes historic commitments to hire and support military spouses - Veterans Affairs)
• Do agencies need new hiring tools to address steep increases in Freedom of Information Act requests? Agencies are struggling to retain FOIA staff and hire new employees to deal with their increasing FOIA backlogs, according to a draft report from the FOIA Advisory Committee. The report found more than half of all FOIA professionals across government consider staffing to be their greatest need. The draft report would recommend that the Office of Personnel Management give agencies direct hire authority for FOIA positions. The committee is expected to vote on the final report in April.
  (With FOIA backlogs on the rise, do agencies need direct-hire authority? - Federal News Network)
• The expert panel Congress chartered to give DoD's Cold War-era budgeting system a tune-up has a lot of ideas. The Commission on Planning, Programming Budgeting and Execution (PPBE) delivered its final report yesterday, after two years of study and hundreds of interviews. All told, there are 28 recommendations that DoD and Congress will need to implement over the next three-to-five years, but the key idea is to replace the slow PPBE process with a more modern one called the "Defense Resourcing System." Read more about the recommendations at Federalnewsnetwork.com.
  (Long-awaited report would replace DoD’s PPBE process with ‘Defense Resourcing System’ - Federal News Network)
• The Government Publishing Office (GPO) has a new senior leader to manage the agency's workforce and human resources office. The agency announced on Wednesday that Beth Shearer will step in as GPO's chief human capital officer (CHCO). Shearer has held various human capital roles over the last two decades, many of which were at GPO. As CHCO, Shearer will be in charge of agency employee policies and human capital initiatives.
  (GPO director names chief human capital officer - Government Publishing Office)
• A new report from the Congressional Budget Office finds that the basic allowance for housing (BAH) for military personnel is higher than what civilians pay for rent and utilities. On average, the BAH rate for E-5 personnel with dependents is about 47% higher than the median rents paid by civilians with similar age and education profiles. The difference narrows to about 20% for civilians with income similar to E-5 personnel. Those service members are usually between the ages of 23 and 28 and hold the rank of sergeant in the Army, Marine Corps and Air Force, and second-class petty officer in the Navy and Coast Guard.
  (BAH rate for military personnel is higher than 'civilians' rent - CBO)
• Federal employees would have to disclose any royalty payments they receive in carrying out their official duties under a new bill advancing in the Senate. The Homeland Security and Governmental Affairs Committee voted 12 to 0 to approve the Royalty Transparency Act on Wednesday. The legislation would also require members of federal advisory committees to disclose potential financial conflicts of interest. And it also requires that public financial disclosure forms for federal employees are made available online.
  (Transparency bill on royalties paid to government officials advances in committee - HSGAC)

The post DoD slated to receive over $18B for military construction initiatives first appeared on Federal News Network.

Multiple-award contracts don’t mean everyone who bids get a slot. A new federal circuit court ruling shows that losing companies can protest those who did get an award and maybe knock them off. For details on this important case, the Federal Drive Host Tom Temin  talked with attorney Stephen Bacon of Rogers-Joseph-O’Donnell.

Interview Transcript: 

Tom Temin So this was protested, not to the [Government Accountability Office (GAO)], but to the court in the first place, the Court of Federal Claims. Tell us what happened here. Who’s suing who?

Stephen Bacon So this was a VA procurement, the [Transformation Twenty-One Total Technology-Next Generation (T4NG)] contract for IT services. Some of your listeners may know there’s a T4NG to second generation contract, that this was the first generation contract, and actually an onramp process where the VA was seeking to add contractors to the first generation of the T4NG contract. And so this protest involved a challenge to that competition for the on ramp.

Tom Temin All right. And they were going to add several. And this one company did not make the cut and protested.

Stephen Bacon That’s right. So the solicitation as is often the case for a multiple award contract, it said that the VA intended to add seven awardees, but it gave the agency flexibility to choose the number of awardees, and the agency ultimately made nine awards to proposals that were either good or outstanding. And REV was rated acceptable and so it didn’t make the cut and then challenged that determination by the VA.

Tom Temin So REV losing company challenged the findings of excellent or good of some of the ones that did get awards. And what grounds did they base that on? What information did they have that would allow them to say, hey, they should have been acceptable like us, or we should have been good like them.

Stephen Bacon So REV actually had two categories of allegations. It’s common in a bid protest. In the first instance, they challenged the VA’s evaluation of their own proposal saying instead of acceptable, we should have been rated either good or outstanding because of flaws in the way that the agency evaluated our proposal. But they also challenged six of the awardees and argued that they should have been eliminated from the competition for one reason or another. They made allegations that some of the awardees had organizational conflicts of interest that should have excluded them, or had some other defect in their proposal that rendered them unacceptable under the terms of the solicitation.

Tom Temin Right. So those are pretty serious findings, organizational conflicts of interests. Something that raises eyebrows. But initially at the Court of Federal Claims, they were just ruled out on jurisdictional grounds, standing grounds, I should say.

Stephen Bacon On standing grounds with respect to the second category of allegations. So in a bid protest, one of the key sort of thresholds that you have to get over is to be able to establish if you have standing to protest, meaning that you have the right to even bring your allegations into court. And so that’s a two part test. The first is to decide whether you’re an actual offer or in the competition that has a direct economic interest in the outcome. That’s typically easy to satisfy as long as you’ve submitted a proposal. But there’s the second part of the test that was really at issue here. And that’s showing that there’s prejudicial error that you’re alleging, in other words, that you can show that there was a substantial chance that you would have received a contract if the agency didn’t make whatever error you’re alleging in the protest. And so that prong of the standing test was really kind of the core issue that the Court of Federal Claims used to say that REV didn’t have standing to challenge the awardees, because in the first instance, it didn’t establish that the agency had made any error in assigning an acceptable rating to its proposal. The court took that finding that there was no error in the acceptable finding. And so even if REV was able to successfully eliminate some of the awardees, the court ruled that it didn’t show that it would have had a substantial chance at winning the contract.

Tom Temin We’re speaking with Stephen Bacon. He’s an attorney with Rogers, Joseph O’Donnell. But then REV went to the Federal Circuit Court on appeal then and got a different finding.

Stephen Bacon That’s right. The Federal Circuit reversed, they brought this issue of standing, REV did, to the Federal Circuit, and the Federal Circuit disagreed with the way that the Court of Federal Claims addressed this standing question in the context of a multiple award contract where there’s no set number of guaranteed awardees. And the circuit disagreed with the Court of Federal Claims logic that if the six awardees that REV had challenged were eliminated, that they wouldn’t have had a substantial chance. The circuit agreed with the protester and said, if you had six of those awardees and they had been eliminated, there would have been room for REV to hypothetically get into the winner’s circle if its right about its allegations.

Tom Temin Well, that’s like the San Francisco 49ers saying, well, if it wasn’t for those people from the Midwest and Kansas City, we would have won the Super Bowl. What is the meaning of that of saying, well, if. Because the if didn’t occur, those companies were rated higher.

Stephen Bacon That’s right. So it’s sort of a hypothetical test that the court engages in to decide whether they’re even going to address the merits of your protest. And so this isn’t ruling in favor of the protester on the merits. It’s just simply saying that the court should have grappled with and decided whether those six awardees should have been eliminated because the Court of Federal Claims just didn’t even reach those issues. And so this decision kicks it back to the lower court to say whether there was an organizational conflict of interest or whether there were some reason that the protester pointed out correctly, potentially, that some of those awardees should have been eliminated.

Tom Temin So at this point, then, FEVS has spent a lot of time and money to break new legal ground, but not necessarily to get that contract.

Stephen Bacon That’s right. This doesn’t mean that they’re necessarily going to get into the winner’s circle, but it gives them another opportunity to go back to the Court of Federal claims and have their, at least at a minimum, have their OCI allegations heard and their allegations that some of the other awardees should have been eliminated, heard. And if that’s the case, if they’re able to prevail on that, then in theory they could get an award.

Tom Temin Right. But does that happen automatically? Once the Federal Circuit Court has rendered its opinion, is it up to the company to carry that back and get a new court date and retry the whole thing at the Federal Court of Claims?

Stephen Bacon That’s right. So it will go back remanded. Is the legal term, remanded to the Court of Federal Claims to then decide those other allegations on the merits based on the administrative record before the court. And if the court rules in favor of the protester, then that typically kicks it back to the agency to then look at the court’s findings. And if the protester was correct, that may change the outcome of the new evaluation that the agency has to conduct to comply with the court’s ruling.

Tom Temin And how long could all that take? By the time T4NG two comes out?

Stephen Bacon That’s one of the curious things about this case is they’re fighting over getting on the onramp on to the prior generation contract. And now there’s already been awards under the second generation T4NG contract. So it’s a little curious to wonder what what their real interest is in here. But I suppose there’s still some runway left on this first generation contract, and they’re hoping they can get on it. If the agency continues to award task orders.

Tom Temin In another domain of adjudicating cases, there is the concept of is this case precedential or is it simply routine application of what we already knew. Is this in some sense precedential?

Stephen Bacon Sure. Any time the Federal Circuit rules on a bid protest issue, I kind of think of them like the Supreme Court of government contracts in a sense. There’s very rarely does a bid protest go all the way up to the actual Supreme Court. So typically, the Federal Circuit is the court of last resort for government contracts. And so any time they rule on this kind of issue, it sets a precedent in this particular area. And here with the proliferation and importance of multiple award contracts, this does provide that helpful clarification that protesters really should have a right to go in and challenge awardees, even where there’s some flexibility that the agency has to make a particular number of awards.

The post Contractors have new grounds to protest their way into a multiple-award contract first appeared on Federal News Network.

The Pentagon’s massive project to overhaul the military’s system for moving members’ belongings from one duty station to another has cleared its latest technical hurdle and is finally ready to begin implementation, government and company officials involved with the multibillion dollar Global Household Goods contract said Tuesday.

A new round of IT integration testing, conducted in January, proved “successful,” Stuart Bradie, the president and CEO of KBR, told investors on a conference call. HomeSafe, the holder of the up to $17.9 billion Global Household Goods Contract (GHC), is a joint venture between KBR and Tier One Relocation.

Problems with integrating U.S. Transportation Command’s systems with the vendors’ technology, called HomeSafe Connect, were the latest hurdle in implementing the moving contract, which Defense officials previously planned to being using for military moves last September. Now that those issues have been ironed out, HomeSafe and DoD intend to start conducting “test moves” involving short-distance shipments this spring, Bradie said.

“The volume ramp will be in a controlled manner through the year with the expectation of significantly ramping up into 2025, especially the busy season and international moves will then follow as we head into 2026,” he said. “So in short, a delay of one year. Though a delay is always frustrating, I believe it has allowed both sides that time to direct the startup and of course the ramp, which ultimately is a good thing.”

On a conference call with reporters later Tuesday, U.S. Transportation Command officials said they intended to begin the test moves as soon as possible. Within the next few weeks, after some final consultations with the military departments, officials plan to publicly announce the first locations where the new moving contract will be implemented for the first time.

The first awards to HomeSafe for actual — albeit short-distance military moves — should be made within the “next couple of weeks,” said Andy Dawson, the director of TRANSCOM’s Defense Property Management Office.

“And then the next steps after local moves will be  interstate moves between installations, and then we’ll look to expand locations,” he said. “And there’s several ways that we can increase the volume. Whether it’s increasing the zip codes around an installation, or increasing those interstate shipments. Our first focus is on the domestic, and that is our initial priority.”

During the upcoming 2024 peak summer season, DoD only expects about 1% of its overall household goods volume to use the new moving contract. From there, it intends to start ramping up its use of GHC within the continental United States starting in September. International moves under the new contract aren’t likely to begin until September 2025 at the earliest.

“We’re finalizing [the timeline] right now, but I think what’s different this year is the ability to do these test shipments and actually see the systems in use,” Dawson said. “We can get feedback and make whatever adjustments are necessary, and that will help us drive the timeline this fall. That’s really the game changer for this summer: these test shipments and the ability to actually see the tools in use.”

Supplier base will be adequate, company says

KBR’s Bradie also sought to reassure investors that HomeSafe will have enough participation from the moving industry to successfully implement the contract. The company does not operate any trucks or employ any movers on its own; it will rely entirely on subcontractors to conduct the work.

Federal News Network reported in January that few, if any of DoD’s current moving providers are willing to take part in the GHC contract, partly because the rates HomeSafe is offering are significantly lower than what DoD is currently paying the companies under its existing moving system, known as DP3. Several traditional movers said they would lose money if they agreed to take shipments under the new rate structure.

But Bradie dismissed those concerns as “media noise.”

“The intent of this program is to redefine the moving experience of our military personnel and their families, and to deploy an IT backbone with intelligence to retain data and knowledge that allows for optimization and importantly, accountability. To achieve this, we require a certain level of disruption and of course, disruption leads to change,” he said. “The objective is to disrupt the industry so it becomes far more competitive and a lot of the middle layers are taken out. We get to focus on the actual truckers and their families, and we help them grow their businesses because they’re performing and they’re accountable. So I expect more noise in that sense. Am I concerned about the rate structure? No, I’m not. I think we will work through that with TRANSCOM.”

Bradie said HomeSafe now has 380 “fully executed” agreements in place with moving subcontractors, and that “several” large van lines have told the company they are willing to commit to working under the new moving contract once the program reaches higher volumes of moves.

Reached by email, a spokesperson for HomeSafe said the 380 companies who have signed on and passed its vetting criteria are a mix of existing military movers and firms with experience only in non-military moves. However, HomeSafe is declining to identify any of those subcontractors.

“Vocal opposition seeking to hinder the GHC roll-out leaves some of our subcontractors reticent to publicly disclose their partnerships with us,” the company said in a statement. “Much of the opposition to the GHC is a push to preserve the status quo, and it neglects to consider why we need the GHC in the first place: to correct longstanding issues with the military move process which have caused military families unnecessary harm and stress. The military community and Congress demanded reform, and HomeSafe is answering that demand.”

Subcontractor capacity remains unclear

Industry experts said it is difficult to know how much moving capacity will be available under the GHC contract without knowing which firms have signed up. They also cautioned that signing HomeSafe’s master services agreement does not guarantee that a given firm will actually conduct moves under the new moving contract.

“We don’t have independent numbers on [signed contracts], but it would seem to me that a signed agreement doesn’t necessarily mean a service provider is compelled to move any shipments just because they signed the agreement,” said Daniel Bradley, the vice president for government and military relations at the International Association of Movers. “Certainly, some of our members have said they signed the agreement as a way to learn more about compensation structure, because there have been times when potential service providers couldn’t get access to view rates without having signed an agreement.”

In a January interview, Matt Dolan, HomeSafe’s president, acknowledged the company faces an uphill battle in persuading moving companies to sign on.

“I’ve got a lot of work to do to convince them,” he told Federal News Network. “I don’t think the whole story has been told, but I think the one thing that’s definite is that this is going forward. TRANSCOM is committed, and we’re committed. Compensation will always be an issue, but TRANSCOM has been a great partner and there are methods to take that into account. I have great friends in industry who give me their straight feelings on it, and I don’t deny any of it. But we think we’ll be successful.”

The post DoD ready to start implementing multibillion dollar moving contract after solving latest tech hurdle first appeared on Federal News Network.

A new rule is expected any time now that will overhaul how the Defense Department buys from the Ability One program. That is the vehicle for non-profit employers of people with disabilities to deliver goods and services to the government. Contractors under the Ability One program worry the new rule will hinder a chief program goal of helping those very employees. To discuss concerns, the Federal Drive Host Tom Temin spoke with Larysa Kautz, the President and CEO of Melwood, which supports children, youth, and adults with disabilities to “work and play where and how they choose.”

Interview Transcript: 

Tom Temin Briefly give us where Melwood fits within the apparatus. That is the Ability One program serving federal agencies and the Defense Department.

Larysa Kautz Sure, Tom. We are one of the tops of the 400 agencies around the country that serve as Ability One contractors. We’re a nonprofit. We’re a leading employer advocate and preferred provider for people with disabilities. We have about 60 different federal contract sites around the D.C. region.

Tom Temin And what types of goods and services do you generally operate with?

Larysa Kautz So we do custodial, we do landscaping. We actually grow all of the flowers for the Kennedy Center in our greenhouses, and we do all the landscaping there. We have a top-secret facility clearance because we make sure that the Attorney General’s office is clean. And the State Department, Fort Meade, we do building maintenance. I like to say that we help run the government.

Tom Temin All right, well, next time I’m at the opera, I’m going to take a close up look at the flowers at the Kennedy Center. And I’ll say, I know where those came from. There is a new rule that is about to come out any day now from the Defense Department. I guess it is from the controlling authorities for Ability One. And you’re concerned that this could make it tougher for companies, nonprofits like yours and disrupt long standing practice? What in general do you expect the rule to look like?

Larysa Kautz So, Tom, you know, the DoD did a review of the Ability One program a few years ago. It was very in-depth, and it had proposals to modernize the program, one of which is to add, a level of competition to the program to ensure that the contractors are performing with excellence and that there’s a chance to do a price competition potentially every five years for the contracts. Now, this has been reviewed by the Ability One Commission and the proposed rule, which is now in its final stages and expected to come out soon, proposes to compete contracts. At least the proposed rule proposes to compete contracts that are above $2 million a year, which will involve a very, very large number of contracts in the program and basically focuses on price, as the main differentiator between non-profits competing for that. It does not look at the biggest bottom line value proposition of the program, which is job creation. And there’s this trade off in the program between price and employment. If we lower our price to the lowest possible amount, we will be hiring the people who are least significantly disabled, who are more productive will be cutting costs with respect to coaching and job coaching and counseling and accommodations. You know, if we really go to the bottom line of lowering price at any cost, it’s not going to help achieve the mission of the program. The program’s bottom-line value is there is a return on investment to the government of this program beyond just the prices that the agencies are spending for the services. We did a study with Virginia Tech last year that showed that the program reduces government spending by about $38,000 per person who has been employed and served by Melwood. But this rule doesn’t take into an account any impact and calculations of that value proposition and what impact it will be to have a lowest price, technically acceptable kind of a shootout between the non-profits and how that will impact the general return on investment. Right.

Tom Temin And that $2 million that you mentioned, contract threshold, that is a significant reduction from the requirement for periodic competition now, which is 10 million.

Larysa Kautz So the 898 panel, which was the DoD panel that proposed competition, they were the ones that set the proposed $10 million floor because, you know, they know that competition is a disruptor, right? This program was created to have long term, stable jobs for people with disabilities. And as long as the nonprofit is performing the work satisfactorily, we keep the contracts. We don’t compete them every five years. And so, they knew that with this change we would have to hire business development people and pricing experts and really fight for the contracts, which in my opinion is a waste of charitable dollars since we’re all nonprofits and we take the margin on these contracts, and we reinvest it in the community. And so, they set a $10 million floor. And they also said that social impact would be considered in the value proposition of the competition. Now, that has been completely left out of this proposed rule, nearly 100 organizations, both the contractors and disability organizations and others provided comments to the proposed rule with respect to both that threshold and the social impact not being part of it. And I’m just hoping that in the final rule that we see some move from the proposed rule back to the way that the DoD originally had proposed it.

Tom Temin We were speaking with Larysa Kautz. She’s the president and CEO of Melwood. And traditionally, people working in the Ability One contractors because they’re disabled, sometimes severely so, have received much lower wages than are prevailing for people that are fully abled under, you know, federal labor law. And there’s been a move in recent years to raise the level of pay that those people receive because reasoning is, well, they’re working and they’re providing value. So why shouldn’t they get the same minimum wage as everyone else? Those two ideas seem to be in collision then, price competition plus, you know, dramatic wage raises for people with disabilities working for the contractors.

Larysa Kautz Absolutely, Tom, and I love that you bring this up, because it’s exactly what the problem is with this proposed regulation. It’s only looking at the price to the customer, and it’s trying to drive down the price to the federal agencies. Meanwhile, in the background, there are policy shifts. There are other regulations being proposed to the program to modernize it, to make sure that everybody’s being paid a competitive wage, to make sure that we shore up as non-profits, the vocational support and counseling that we do. A lot of those things are now becoming a priority and a requirement of the program. But at the same time, this regulation doesn’t take any of that into account. If there was a balance in the regulation where social impact and price and technical proposal and past performance, if all of those were weighted equally, then the government would truly get the best value and the best benefit from each of those contracts. But really, truly just focusing on price, I think it doesn’t acknowledge the real mission of this program, which is good jobs for people that are the most significantly disabled.

Tom Temin And in a practical sense, these are not big-ticket items in defense terms. I mean, it’s not like you’re supplying them the next generation of bomber, which has, you know, $1 trillion lifecycle cost. It’s services like you say, landscaping, cafeterias, flowers, pens and pencils, that kind of thing.

Larysa Kautz It’s significantly less than 1% of the DoD’s budget. I mean, we’re talking about half of a percent of the DoD budget. And there’s been so much time and effort and energy involved to really think through how to put competition into this program when I just, you know, we just did a renegotiation for our Fort Meade contract. We saved the government $24 million over a five-year period by sitting across the table, opening up all of our books, really talking to them about the services that they need on the ground. And we even, you know, we got a write up in an article that said that they really were extremely satisfied and surprised by sort of that open kimono type of negotiation. That’s what’s possible in this program, and that’s how this program was designed to run. I think by moving backwards to less transparency, to more competition with people bidding bare minimum amounts for the scope of the contract as it’s drafted, which then leads to misperceptions, modifications to the contracts, you know, actually more money in the long run that’s wasted in contract administration and right sizing the contract after the fact. I just wish that that had been investigated and quantified and thought about. But there really isn’t much in this rule that shows a cost benefit calculation in those terms.

The post Contractors say new AbilityOne Commission rule could undermine people with disabilities first appeared on Federal News Network.

Brian Goodger, the NITAAC director, said NITAAC is planning to keep CIO-SP3 open through October 29 and have the option for another six months after that, if necessary.

“The justification for approval to continue the contract still needs a final sign off,” Goodger said at the AFCEA West conference yesterday. “If you are on the CIO-SP3 contract vehicle, once the extension is approved, it will run through the entire fiscal year.”

Goodger said the reason for the new extension is, once again, because of protests holding up the CIO-SP4 governmentwide acquisition contract (GWAC). He said the vehicle is facing six new protests before the Court of Federal Claims, and resolving those complaints could take up to a year.

“Those six are represented by the same one or two law firms. This Friday we will find out which judge is appointed by the COFC,” Goodger said. “That is important because some judges tend to side with the government and others tend to side with industry so we may be able to discern where this latest set of protests are going.”

Should this extension go through, it would push the expiration date of CIO-SP3 more than two years past the original sunset date of May 2022.

The six protests bring the total number of protests above 350 in two plus years. NITAAC has won a majority of the complaints.

The latest round of complaints came after Goodger said NITAAC alerted 464 vendors in January that they had tentatively met requirements of the contract for award, and now NITAAC is doing their due diligence before making a final award decision.

“We rescored and revalidated the bids that we got last fall,” he said. “The number of points needed to meet the threshold to win a spot on the contract went down. We increased the number of potential winners from 431 to 464.”

NITAAC’s CIO-CS gets new name

While NITAAC continues to push the CIO-SP4 contract across the finish line, Goodger said it’s about to start the hard work on the follow-on to the CIO-CS vehicle.

He said, first off, NITAAC is changing the name of CIO-CS from CIO Commodities and Solutions to CIO Commodities Store.

NITAAC awarded the 10-year CIO-CS GWAC to 64 companies, all value-added resellers (VARs) or other equipment manufacturers (OEMs) in 2015. CIO-CS is an IT products contract for end-user hardware and software as well as several other commercial technologies.

“I expect the number of awards to go up by 30% or 40% with an equal proportion of VARS and OEMs,” Goodger said.

He said NITAAC will issue a sources sought notice for the next version of CIO-CS in late March. The acquisition organization doesn’t plan on issuing a draft request for proposals, and plans to release the final solicitation in the June or July time frame.

Goodger said NITAAC expects to make awards by late January 2025, and if all goes well, the new CIO-CS contract would start by May.

He said NITAAC likely will not use a self-scoring sheet, and it will be based on best value evaluation factors and not lowest-price, technically acceptable (LPTA).

“We expect CIO-CS to get fewer proposals than CIO-SP4,” he said. “We likely will not have an on-ramp because the interest isn’t there for products like it is for services. But we will have an off ramp for those companies that are not competing or have not won any task orders and are not complying with the administrative requirements after a year or two.”

Goodger said NITAAC is paying attention to the experience of the Department of Homeland Security  and its FirstSource III contract, which similarly is for IT products. DHS is in its third year of trying to award this contract with a $1.5 billion ceiling. He said NITAAC met with DHS acquisition officials recently to discuss their approach and challenges to FirstSource III.

CIO-CS has been a fairly successful contract with more than $2.3 billion in obligations over the nine years, well under the $20 billion ceiling. By contrast, CIO-SP3 received more than $5 billion in obligations last year alone.

The post NITAAC seeking another 6-month extension for CIO-SP3 first appeared on Federal News Network.

The issue of whether the small business rule of two “shall” apply to orders goes back to the codification of the MAC concept in the Federal Acquisition Streamlining Act of 1994. Initially, the consensus was that the rule of two applied at the contract level, considering the fair opportunity requirements that apply to MACs. Over the decades, there have been size protests, bid protests, reports to Congress, proposed and final regulations, as well as proposed and actual legislation, trying to settle once and for all whether the rule of two must be followed prior to placing an order or choosing a contract vehicle. The OMB memo, which is not a regulation and did not go through the traditional notice and comment procedures required by the Administrative Procedures Act, raises multiple operational and policy questions.

Is there an actual need for the policy? In fiscal year 2022, the Federal government awarded small businesses a record $162 billion, or 26.5%, of all contract dollars. [1] The Federal government has met or exceeded the statutory 23 percent small business goal for the last decade. Small businesses are doing even better under best-in-class MACs, receiving approximately 38% of the total dollars awarded. [2] Small businesses received 40% of the dollars awarded under the professional services OASIS MAC [3] and over 31% of the total dollars awarded on the information technology services CIO-SP3 MAC. [4]

Is this a cardinal change to the contract, such that large and medium-sized businesses should be entitled to adjust pricing to cover lost opportunity? These businesses competed for and priced these contracts based on an historic, expected level of competition and opportunity that will no longer exist.  This is especially significant for medium sized businesses that rely on MACs for procurement opportunities.

Will contract costs increase as a result of less competition? The scope of current MACs has essentially been expanded for small businesses as they no longer need to compete with large and medium-sized businesses for certain orders. Does the Federal government need to renegotiate lower contract prices from small businesses to account for this new, expanded set-aside within an existing MAC?

If small businesses are on a full and open MAC, presumably they can perform all orders under the scope of that contract. Under these circumstances, when will MAC orders not be set aside? Can an agency using a full and open MAC that includes small businesses ever successfully make a determination not to set aside an order? Simply put, the award of prime contracts to multiple small businesses under a full and open MAC is a determination that the small businesses can do the work.    Similarly, to the extent agencies have awarded side-by-side set-aside and full and open MACs (such as OASIS), will agencies ever use the full and open contract?

To what extent will the memo result in increased litigation and procurement delays arising from challenges to the contracting officer’s business judgment on the capabilities or fair market prices of small businesses? Similarly, SBA’s rules require size recertification on set-aside orders under full and open contracts. Are procuring agencies ready for the additional delays associated with size protests and appeals, which may end up in Federal Court if a party does not like the SBA’s size protest and appeal decision?

Does the memo implement congressional intent? In 2010, Congress attempted to address the issue and implement a recommendation from a 2007 Report to Congress by stating that agencies “may” set aside orders under MACs for small business. The courts and GAO are split on the interpretation of the 2010 statutory language, and Congress has not acted to further address the question.

Putting aside potential Administrative Law issues, is it fair or good public policy to impose such a momentous policy through a memo without the notice and comment that applies to traditional rulemaking? The memo likely will impact the majority of Federal contractors that employ millions of individuals around the country and world. Moreover, the very questions raised here are of a type that the regulatory notice and comment process, in part, is designed to address.

Streamlining regulations, reporting, and procurement processes will do more to attract new small entrants to participate in the Federal market. It is the regulatory and compliance burden that is driving small businesses from the market or preventing them from entering in the first place. These barriers to entry are simply too high and too costly for many small businesses.

For the benefit of government and industry, the agency may wish to consider pausing its implementation of the memo and engaging with all stakeholders to address the government’s goals and the memo’s impact.

The post OMB Memo on Increasing Small Business Participation on Multiple-Award Contracts first appeared on Federal News Network.