On February 10, 2017, the GSA released a Request for Information (RFI) for government-wide entity identification and validation services. The GSA is exploring options for replacing Dun and Bradstreet (D&B), who is the current provider of entity identification and validation services through the use of D&B’s Data Universal Numbering System Number or DUNS number.
Currently, the government requires the assignment of a DUNS number for the identification of commercial, nonprofit, or government entities. All government contractors are required to obtain and maintain a DUNS number to do business with the government in order “to better trace Federal dollars from appropriation to final outcomes or results.”
Not following the terms and conditions of your GSA Schedule Contract can cost you big $$$!
Scenario One: You receive an RFQ from a Federal Government procuring agency that will utilize your GSA Schedule contract on a re-compete for work your company is already performing for this customer. The RFQ lists the labor category title, education and experience requirements for the work, including a Senior Network Engineer that requires a Bachelor’s Degree and 10 years’ experience. Your Senior Network Engineer GSA labor category requires a Bachelor’s Degree and 8 years’ experience, but the person you are proposing in the category is familiar with the work being performed at the agency. The agency’s personnel are familiar with this resource and like the work that she has done in the past. The agency personnel say, it’s fine if you use your person with 8 years’ experience as a substitute for our agency requirement of a person with 10 years’ experience. It sounds harmless enough. The agency has agreed, so you’re in the clear, right? Wrong!
In its Semiannual Report to the Congress for the period from April 1, 2015 to September 30, 2015, GSA’s Office of Inspector General (OIG) warns the agency faces major challenges in pricing and contractor compliance within the Schedules Program. The OIG reached this conclusion based, in part, on the results of the 30 GSA Schedule pre-award audits performed during the reporting period on contracts with an estimated value in excess of $3.1B. Of the total estimated value, the OIG recommended that $195M be put to better use.
The GSA Schedule contracts continue to generate significant sales and the OIG cites commercial sales practice disclosures and Price Reductions Clause monitoring as significant risk areas. Recently, OIG auditors have also focused their attention on labor categories and ensuring that contractors are fulfilling tasks orders with personnel who meet the qualifications stated on their GSA Contract. Significant findings in the audits from this period included (1) commercial sales practices information that was not current, accurate or complete; (2) proposed labor rates that were overstated; (3) ineffective Price Reductions Clause compliance monitoring; and (4) the use of unqualified labor.