Author Archives: Sonia Pesantes

About Sonia Pesantes

Sonia Pesantes is a managing consultant in Aronson’s Government Contract Services Group, where she leads clients successfully through the GSA Multiple Award Schedules (MAS) lifecycle. From obtaining a new GSA Schedule contract acquisition to administering ongoing GSA schedule contracts, she works closely with clients to tailor solutions that meet current and future organizational needs. She has more than 10 years of experience in GSA Schedule support, including development of scope and pricing strategies, contract compliance, audit support, and contract profitability strategies. Sonia earned her bachelor’s degree from George Mason University.

Sonia Pesantes

GSA Collaborating with DHS to include CDM Tools on Schedule 70

GSA collaborating

The General Services Administration (GSA) is collaborating with the Department of Homeland Security (DHS) to add a Special Item Number (SIN) for Continuous Diagnostics and Mitigation (CDM) Tools to Schedule 70. This will allow agencies access to network monitoring products and services to safeguard federal networks. The new SIN will replace a large GSA Blanket Purchase Agreement (BPA) for CDM Tools and Continuous Monitoring as a Service that expires on August 11, 2018.

GSA is working closely with DHS since the Office of Management and Budget (OMB) delegated DHS authority to oversee and assist cybersecurity initiatives across the government. As part of this effort, GSA awarded the CDM BPA to 16 contractors in 2013. The BPA consists of 15 Tool Functional Areas and 11 Service Task Areas. Presently, there are approximately 170,000 products from around 150 manufacturers available on the BPA. BPA sales to-date are in excess of $650 million.

In March 2017, GSA issued a Request for Information (RFI) to gather input from industry regarding the proposed CDM SIN and to gain a better understanding of what CDM Tools are commercially available. The RFI noted that the CDM Tools SIN is replacing the current BPA in order to:

  • Establish a government-wide solution to provide a consistent set of CDM tools;
  • Enhance a contractors’ ability to bring new and innovative solutions;
  • Improve access to the best available technology and improve the flexibility of the program;
  • Streamline the requirements from 15 Tool Functional Areas (TFAs) to 5 subcategories; and,
  • Establish and maintain a list of approved CDM products with a mechanism to qualify new products against the CDM requirements and add products to an Approved Product List (APL).

GSA shared feedback on the RFI with industry at a CDM Tools Industry Day held on April 17, 2017. RFI responses reflected that 72% of respondents agreed there was a need for the SIN. Additionally, 52% of RFI respondents were currently on the on CDM BPA. The general consensus is that the proposed SIN offering is properly formulated and covers the intent in streamlining how CDM tools are sold.

GSA anticipates that the CDM Tools SIN draft solicitation will be posted to GSA Interact in June 2017 and plans to include the requirements to add the SIN to the GSA IT70 solicitation by early this summer. Offerors proposing the new CDM SIN will be eligible to participate in GSA’s FASt Lane initiative.

If you have questions or concerns about recent GSA Developments or your GSA schedule, please contact Hope Lane at 301.231.6266 or hlane@aronsonllc.com.

Additional Small Business Subcontracting Plan Compliance Requirements Underway

Significant regulatory changes instituting small business subcontracting improvements have been incorporated into the Federal Acquisition Regulations (FAR), imposing additional small business-related obligations on large prime contractors (“Prime”). Although these changes went into effect on November 1, 2016, businesses may not experience their full impact until later this year. Existing government systems, such as the Electronic Subcontracting Reporting System (eSRS), need to be modified to accommodate several of these compliance requirements.

The GSA has started incorporating the updated FAR clauses containing these provisions into its Schedule solicitations via refreshes and mandatory modifications. The most significant changes being implemented are as follows:

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From the GSA Trenches: Contracting with Other GSA Eligible Users

Does your business development team know who your GSA customers are?  In a previous From the GSA Trenches blog, we shared guidance on working with prime contractors pursuant to FAR 51.   Today we are providing further guidance on eligible users based on inquiries from clients. Recently, several clients have asked about contracting with national laboratories and whether they would be distinguished as GSA sales, specifically when contracting relationship with these customers appear quasi in nature and unclear.

To first summarize, per GSA Order ADM 4800.2H, eligible activities are defined as organizations that have been authorized by statute and/or regulation to use the GSA Schedules as Sources of Supply and Services. Eligible activities are categorized into the following subcategories, which also define the organization’s limitations and accessibility to GSA’s Schedules program:

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From the GSA Trenches: Don’t Overlook Compliance with the FAR 51 Deviation

At a recent Contractor Assessment, a few of the compliance errors pertained to the Federal Acquisition Regulation (FAR) Part 51 Deviation, a seldom-monitored area that causes some level of confusion for many contractors. Although there may be several reasons why this happens, one of the most frequent is that the contractor failed to distinguish transactions under the deviation as GSA sales. Contractors may not know what constitutes a GSA sale, may have not offered GSA pricing to a GSA eligible buyer, and/or they may not have a proper system in place to track documentation and identify GSA sales.

In accordance with FAR Part 51.1, Contractor Use of Government Supply Sources, contractors can be given the authority to make purchases against Federal Supply Schedule (FSS) contracts on behalf of the government. This usually occurs for large-scale projects when a contractor needs to purchase products and/or services in order to provide a total solution for an agency. The federal government will include clause 52.251-1, Government Supply Sources, in solicitations to indicate to prospective contractors that items procured under the deviation may be proposed.

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From the GSA Trenches: Resume Reviews Aim to Identify the Utilization of Unqualified Personnel on GSA Orders

In attending recent GSA Contractor Assessment s these past several months, our team has noted an increased emphasis by GSA Industrial Operations Analysts (IOAs) on reviewing resumes. This practice impacts contractors with labor categories currently awarded on their schedule contracts. GSA requires each approved labor category to have a description that includes the minimum experience, minimum education and functional responsibility for the category. The hourly rate for each category is negotiated, in part, based on these qualifications.

The GSA Inspector General has noted on reports to Congress on the Schedules Program that the utilization of unqualified labor is a common finding during audits. As a result, IOAs are requesting to review resumes, timesheets, and other personnel documentation to compare and ensure that the contractor provides individuals who meet or exceed the level of experience and expertise approved on your GSA contract. Please note that this review may include subcontractor employees mapped to awarded labor categories on the prime’s GSA contract.

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