The Coalition for Government Procurement

Today, one of the top procurement “buzz words” has to be “innovation.” It seems that every day departments and agencies across the federal government are seeking “innovation” in one form or another. We have seen the Department of Health and Human Services establish a new Buyer’s Club to promote innovative procurement practices, and along these lines, the Department of Homeland Security established a Procurement Innovation Lab. GSA continues to tout the work of 18F, its innovation lab, and, in a recent talk, Secretary of Defense Ash Carter focused on the Department’s need to gain access to Silicon Valley’s innovative technology companies. The Office of Management and Budget also continues to explore opportunities to bring innovative firms to the federal market, including proposing a new “innovation” set-aside authority.

Administrator Anne Rung’s December 4, 2014 memorandum “Transforming the Marketplace: Simplifying Federal Procurement to Improve Performance, Drive Innovation, and Increase Savings,” best sums up the government’s desire for “innovation.” It states, in part, that “[o]pening the acquisition system to greater innovation is critical to ensuring best results in contracts. We must embrace practices that encourage new and better ways of thinking and expand access to the most innovative companies.” To the extent the current focus on “innovation” shines a light on cross-cutting, systematic challenges in the procurement system, it is a positive development that can lead to real opportunities for procurement reform. In the spirit of OFPP’s historic Myth-Busters initiative, here are five practices that should be embraced to improve the efficiency and effectiveness of the procurement system:

  • Reduce/Cut Red Tape. Cutting red tape means putting “commercial” back into commercial item contracting, addressing contract duplication, and minimizing the use of government-unique requirements to the maximum extent practicable.
  • Improve Market Research & Requirements Development. Simply put, market research and requirements development are the “blocking and tackling” of procurement. As recognized by countless advisory reviews over the years, improvement here would provide the single most effective way to increase the efficiency and effectiveness of the procurement system.
  • Reinvigorate Performance-Based Contracting. Despite years of emphasis, the potential of performance-based contracting has yet to be fulfilled. Performance-based contracting can drive government access to the creativity of the commercial market place, increase competition, and achieve greater efficiencies and savings for customer agencies.
  • Address Organizational Conflicts of Interest. Companies who bring new ideas to government or otherwise assist agencies in identifying/articulating needs should not be precluded from competing for related work.
  • Empower the Acquisition Workforce. Management needs to be there to support the acquisition workforce. The acquisition workforce needs professional development support, not another process, to perform its mission.

The central goal of the procurement system is the efficient and effective acquisition of products, services and solutions to meet customer agency mission requirements.   The appropriate product, service or solution will depend on the underlying requirements of the customer agency.

It is through a well-functioning system that the “innovation” sought by government leaders will be facilitated, appropriate to the underlying requirement. To assist in promoting such a system, over the rest of 2015, the FAR & Beyond Blog will devote blogs to each of the identified practices.

 

 

Before the July 4th holiday, the Department of Veterans Affairs (VA) National Acquisition Center (NAC) held its VA NAC Industry Days conference in Chicago. It was a great opportunity for Federal Supply Schedule (FSS) contractors that hold pharmaceutical and medical product and service contracts to hear from VA acquisition leaders about their current priorities and initiatives. FSS contractors also had the unique opportunity to have one-on-one meetings with their contracting officers during the industry days. The VA NAC is to be commended for all their hard work in putting together the conference. It was a tremendous first step in the Mythbuster’s dialogue on how to most efficiently and effectively deliver best value products and services to our nation’s veterans.

One point made during the Keynote by Executive Director of the VA Enterprise Program Management Office, Greg Giddens, particularly resonated with me. It was the “two thumbs test” that the VA is using in decision-making these days under Secretary Robert McDonald. The two thumbs up test is whether something is 1) good for veterans and 2) good for the taxpayer. At the Coalition, we are committed to advocating for common sense solutions that improve the Federal acquisition system for both the government and its industry partners. In the case of the VA, a more efficient and effective procurement system could deliver pharmaceuticals and innovative commercial medical products and services to our veterans faster—and at a better value to taxpayers. Now that’s a “two thumbs up!”

You may be aware that members of the Coalition’s Healthcare Committee are currently developing a supplemental to our MAS Pricing Policy white paper focused on pricing and policy matters unique to VA Schedules. We hope that the recommendations made in the white paper will serve to continue the dialogue with the VA on many of the topics discussed during the NAC Industry Days, such as:

  • how to best leverage the Schedules program to get veterans the medical products and services they need at a best value to taxpayers,
  • how contract procedures may be modified in consideration of VA customer preferences and demand for innovation, and
  • how to increase efficiencies and reduce the cost of acquisition for all stakeholders.

The Coalition also looks forward to continuing the dialogue with the VA’s NAC and the Strategic Acquisition Center (SAC) regarding the vision and objectives for the Medical/Surgical Prime Vendor program. Again, we sincerely appreciate the VA’s acquisition leadership for launching the dialogue on these important topics at the VA NAC Industry Days in Chicago.

Happy 4th of July!

July 2nd, 2015

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Members,

This week the FAR & Beyond Blog and the Friday Flash are dedicated to the Fourth of July.

The blog highlights excerpts from a speech given by President Kennedy at Independence Hall, Philadelphia, July 4, 1962.

We hope everyone has a wonderful July 4th weekend!

It is a high honor for any citizen of our great Republic to speak at this Hall of Independence on this day of Independence. To speak as President of the United States to the Chief Executives of our 50 States is both an opportunity and an obligation. The necessity for comity between the National Government and the several States is an indelible lesson of our long history.

Because our system is designed to encourage both differences and dissent, because its checks and balances are designed to preserve the rights of the individual and the locality against preeminent central authority, you and I, Governors, recognize how dependent we both are, one upon the other, for the successful operation of our unique and happy form of government. Our system and our freedom permit the legislative to be pitted against the executive, the State against the Federal Government, the city against the countryside, party against party, interest against interest, all in competition or in contention one with another. Our task–your task in the State House and my task in the White House–is to weave from all these tangled threads a fabric of law and progress. We are not permitted the luxury of irresolution. Others may confine themselves to debate, discussion, and that ultimate luxury–free advice. Our responsibility is one of decision–for to govern is to choose.

Thus, in a very real sense, you and I are the executors of the testament handed down by those who gathered in this historic hall 186 years ago today. For they gathered to affix their names to a document which was, above all else, a document not of rhetoric but of bold decision. It was, it is true, a document of protest–but protests had been made before. It set forth their grievances with eloquence–but such eloquence had been heard before. But what distinguished this paper from all the others was the final irrevocable decision that it took–to assert the independence of free States in place of colonies, and to commit to that goal their lives, their fortunes, and their sacred honor.

Today, 186 years later, that Declaration whose yellowing parchment and fading, almost illegible lines I saw in the past week in the National Archives in Washington is still a revolutionary document. To read it today is to hear a trumpet call. For that Declaration unleashed not merely a revolution against the British, but a revolution in human affairs. Its authors were highly conscious of its worldwide implications. And George Washington declared that liberty and self-government everywhere were, in his words, “finally staked on the experiment entrusted to the hands of the American people.”

This prophecy has been borne out. For 186 years this doctrine of national independence has shaken the globe–and it remains the most powerful force anywhere in the world today. There are those struggling to eke out a bare existence in a barren land who have never heard of free enterprise, but who cherish the idea of independence. There are those who are grappling with overpowering problems of illiteracy and ill-health and who are ill-equipped to hold free elections. But they are determined to hold fast to their national independence.

***

The theory of independence is as old as man himself, and it was not invented in this hall. But it was in this hall that the theory became a practice; that the word went out to all, in Thomas Jefferson’s phrase, that “the God who gave us life, gave us liberty at the same time.” And today this Nation–conceived in revolution, nurtured in liberty, maturing in independence–has no intention of abdicating its leadership in that worldwide movement for independence to any nation or society committed to systematic human oppression.

As apt and applicable as the Declaration of Independence is today, we would do well to honor that other historic document drafted in this hall–the Constitution of the United States. For it stressed not independence but interdependence–not the individual liberty of one but the indivisible liberty of all.

***

On Washington’s Birthday in 1861, standing right there, President-elect Abraham Lincoln spoke in this hall on his way to the Nation’s Capital. And he paid a brief but eloquent tribute to the men who wrote, who fought for, and who died for the Declaration of Independence. Its essence, he said, was its promise not only of liberty “to the people of this country, but hope to the world . . . [hope] that in due time the weights should be lifted from the shoulders of all men, and that all should have an equal chance.”

On this fourth day of July, 1962, we who are gathered at this same hall, entrusted with the fate and future of our States and Nation, declare now our vow to do our part to lift the weights from the shoulders of all, to join other men and nations in preserving both peace and freedom, and to regard any threat to the peace or freedom of one as a threat to the peace and freedom of all. “And for the support of this Declaration, with a firm reliance on the protection of Divine Providence, we mutually pledge to each other our Lives, our Fortunes and our sacred Honor.”

Have a fun and safe weekend! The Friday Flash will return on July 10.

Roger Waldron

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President

It is with a sense of both honor and sadness the Coalition announces that Carolyn Alston, our Executive Vice President and General Counsel, will be retiring in July. We are very excited and happy for Carolyn as she begins a new adventure in her life! At the same time, we will miss her professionalism, commitment and drive to bring common sense acquisition policies and procedures to the federal marketplace.

Carolyn’s government service, private sector career and contribution at the Coalition stand as the embodiment of “Excellence in Partnership.” She works diligently, patiently and respectfully with all parties towards common sense solutions that deliver best value for customer agencies and the American people. Her recognition of the motivations, constraints and opportunities each party brings to specific situations has served Coalition members well!

Written words of thanks are not enough—that is why we will be honoring Carolyn for her service to the procurement community at the Coalition’s Excellence in Partnership ceremony on October 21st . I look forward to seeing you all there!

Rest assured the Coalition is moving to fill Carolyn’s position. And although Carolyn is retiring from full time work, we look forward to working with her on future “special projects” supporting the Coalition’s common sense procurement agenda.

On a personal note, fifteen years ago Carolyn gave me a wonderful opportunity to move into “operations” at GSA. I will be forever grateful as it opened a whole new career path for me. And one of my greatest joys was to return the favor and bring her into the Coalition! It has been a wonderful three years! Thank you Carolyn, it has been an honor to work with you! God Bless You!

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The Federal Acquisition Service’s  (FAS’s) Competitive Pricing Initiative (CPI) is intended to address price variability for identical items under competing Multiple Award Schedule (MAS) contracts.  An unintended, positive consequence of this effort has been to highlight questions and concerns regarding the impacts of unauthorized resellers in the MAS program.

Under CPI FAS is collecting pricing information for identical items from GSA Advantage and DoD EMALL, comparing the relative pricing, and providing the information to specific MAS contractors.  In doing so, FAS is seeking feedback from MAS contractors regarding the rationale for their pricing and its relative standing as compared to other MAS contractors.  The current effort does not address unauthorized resellers and/or gray market items under MAS contracts.  However, based on member feedback, unauthorized resellers and grey market items are being included in GSA’s horizontal price analysis and can and do distort pricing in the MAS marketplace.

Moreover, unauthorized resellers and grey market items also raise questions regarding fair competition, intellectual property rights, Trade Agreements Act (TAA) compliance and cyber security.  In particular, as recent events have shown, cyber security concerns must be addressed.  The good news is that GSA is developing a cyber acquisition risk profile for agencies to apply when buying products and services.  Further, DoD and GSA have already identified the importance of purchasing from authorized resellers as key to mitigating cyber risks across the Federal government.  We look forward to engaging GSA’s Emile Monette, Senior Advisor for Resilience and Cybersecurity, Office of Government-wide Policy and other stakeholders on cyber security acquisition requirements.  At the same time, as the manager of the government-wide MAS program, GSA could take a big step in cyber protection by proactively addressing unauthorized resellers and grey market items under MAS contracts.  Such a step would increase both customer and contractor confidence in the MAS marketplace (it would also increase contractor confidence in the CPI).

NASA SEWP’s Statement of Work includes a paragraph addressing Supply Chain Management and the relationship between the contractor and manufacturer.   Paragraph C.1.3.7 provides that in order for the Government to assess the security and risks associated with supply chain management, contractors are required to submit certain information and make certain representations.   Under the clause an authorized reseller is one where the manufacturer has a direct relationship with the contractor and is officially identified as a reseller for the manufacturer.  An authorized reseller must provide a point of contact for the manufacturer who verifies their status.  In addition, an authorized reseller may identify standards/certifications held by the manufacturer that mitigate, reduce or eliminate supply chain and related security risks.  If the contractor is not a manufacturer and/or has not identified themselves as an authorized reseller then the contractor must either identify the source of the item as unknown or identify a  third party source or provide information on the provenance or product level authorization that mitigates risk.

Under IT Schedule 70 and other product-based schedules, GSA requires a letter of supply submitted on the manufacturer’s letterhead and signed by a corporate official of the manufacturer.  The differences between the NASA requirement and IT Schedule 70 are slight but the NASA paragraph provides greater assurance regarding supply chain management.  In particular, the NASA paragraph/requirement provides greater transparency and assurance for grey market items.

Customer agencies and contractors rely on FAS to ensure contract compliance and the overall integrity of the MAS marketplace.  Addressing unauthorized resellers and grey market items is vital to effectively and securely supporting agency missions for the American people.  Addressing this issue is also necessary to assure valid price comparisons in GSA’s competitive pricing initiative.  The Coalition looks forward to working with FAS on this important issue.

By Angela Styles, Steve McBrady, and Jason Crawford

Crowell & Moring

On May 28, 2015, the Obama Administration published the proposed rule and guidance implementing the “Fair Pay and Safe Workplaces” Executive Order, (“EO”) which President Obama issued on July 31, 2014.  The stated purpose of the EO is to ensure that parties who contract with the federal government understand and comply with labor laws.  The underlying goal of the EO may be well-intentioned, but in practice, the proposed rule and guidance will be unworkable and may unfairly exclude responsible companies from doing business with the federal government.  These new regulations will not take effect until the final rule and guidance are issued, but the proposals offer insight into the onerous compliance and reporting burdens that contractors could face starting in late 2015 or early 2016.

Applicability of the “Fair Pay Safe Workplaces” Requirements

The proposed rule adds a new subpart to the Federal Acquisition Regulations (“FAR”) – subpart 22.20 “Fair Pay and Safe Workplaces” – which incorporates proposed guidance issued by the Department of Labor (“DOL”).  Under proposed FAR 22.2004, contractors bidding on contracts valued over $500,000 would be required to disclose whether there has been any “administrative merits determination,” “arbitral award or decision,” or “civil judgment” – key terms defined by the DOL in its Proposed Guidance –rendered against the contractor within the preceding three-year period for violations of enumerated labor laws.  Under the proposed rule, contractors would also be required to report similar information for subcontractors on subcontracts (other than commercially available off-the-shelf items) valued over $500,000.  Disclosure of basic information about the labor violations will be made publicly available in the Federal Awardee Performance and Integrity Information System.

Under proposed FAR 22.2002, the definition of applicable “labor laws” includes the following statutes and executive orders: Fair Labor Standards Act; Occupational Safety and Health Act; National Labor Relations Act; Americans with Disabilities Act; Family and Medical Leave Act; Title VII of the Civil Rights Act; Age Discrimination in Employment Act; Davis-Bacon Act; Service Contract Act; Section 503 of the Rehabilitation Act; Vietnam Era Veterans’ Readjustment Assistance Act; Migrant and Seasonal Agricultural Worker Protection Act; Executive Orders 11246 (Equal Employment Opportunity) & 13658 (Contractor Minimum Wage); and “equivalent state Llaws” as defined by DOL.  In a notable departure from the EO, and likely in response to contractor concerns, the only “equivalent state laws” identified in this proposed rule are OSHA-approved state plans. According to the proposed rule and guidance, the FAR Council will publish a subsequent proposed rule that further identifies “equivalent state laws.” Thus, one of the key questions unanswered by the EO remains unanswered with publication of the proposed rule and guidance.

The magnitude of the reporting requirement is compounded by the fact that the proposed rule requires COs to repeat the responsibility analysis every six months during contract performance.  In fact, contractors must report new decisions and determinations even if they arise from a violation of labor law that was already reported.  Proposed FAR 22.2004-3 lists the options available to a CO upon learning of a violation during performance—i.e., a CO can decide not to exercise an option, terminate the contract, or make a referral to the agency suspending and debarring official.

Insight into Role of the new “Agency Labor Compliance Advisor”

Proposed FAR sections 22.2004-2 and 22.2004-3 address the newly established role of the Agency Labor Compliance Advisor (ALCA).  Federal agencies are required to designate a senior agency official to serve as an ALCA, a position tasked with facilitating contractor compliance with labor laws, and “helping” agency officials determine the appropriate response to address violations.  Under proposed FAR 22.2004-2, the ALCA is to provide the CO, within three business days after a request by the CO, a recommendation that (1) the contractor “could be found to have a satisfactory record of integrity and business ethics;” (2) the contractor could be found to have such a record “if the process to enter into a labor compliance agreement” with the DOL is initiated; or (3) the contractor does not have a satisfactory record of integrity and business ethics and “the agency Suspension and Debarring Official should be notified.”  As a practical matter, it will likely be difficult—if not impossible—for ALCAs to adequately evaluate disclosures about violations of complex labor laws within the three-day window.

Proposed FAR Rule Relies Heavily on DOL Guidance

The FAR Council and DOL published the proposed rule and guidance on the same day under separate notice so that respondents can “consider the documents holistically in addition to offering comment on the specifics of each document.”  In fact, the two documents have to be read together because the key events that trigger a responsibility determination—“administrative merits determination,” “arbitral award or decision,” or “civil judgment” are defined in the DOL proposed guidance.  Moreover, a sizable portion of the 106-page DOL guidance is devoted to defining  the terms “serious,” “repeated,” “willful,” and “pervasive” and explaining how violations of the labor laws should be weighed.  Notably, the proposed guidance defines “serious” violations to include those in which an assessment of at least $10,000 in back wages is “imposed by an enforcement agency or a court.” The proposed guidance also defines “serious” violations to include those in which the contractor “engaged in adverse employment action” (including discharge, refusal to hire, suspension, demotion or threat) or is responsible for unlawful harassment against one or more workers for exercising rights protected by the enumerated labor laws.

 

Implementation of the Paycheck Transparency and Dispute Resolution Provisions

            Proposed FAR 22.2005 will implement the EO’s “paycheck transparency” provision which requires contractors performing work on covered contracts and subcontracts to provide employees covered by the FLSA, the Davis Bacon Act, the Service Contract Act, or “equivalent” state laws, with information concerning the individual’s pay, hours worked, overtime hours, if applicable, and any additions made to or deductions made from the individual’s pay.  The proposed rule also requires contractors to provide to any independent contractors performing work on the contract a document informing them of their status as independent contractors.

Proposed FAR 22.2006 will implement the EO’s “dispute resolution” provision on contracts over $1 million and will require contractors to agree that the decision to arbitrate claims arising under title VII of the Civil Rights Act of 1964 or any tort related to or arising out of sexual assault or harassment may only be made with the voluntary consent of employees or independent contractors after such disputes arise.  The proposed rule lists some narrow exceptions to this requirement including an exception for certain pre-existing arbitration agreements.

What Comes Next?

Based on the impact of “Fair Pay and Safe Workplaces” on the contracting community, contractors will want to consider submitting comments during the 60-day comment period which began running on May 28th.  Several respondents have requested an extension of time to file comments, but for now, interested parties should plan on submitting comments by July 27, 2015.  After the close of the comment period, the FAR Council and DOL will make final changes and resubmit the rule and guidance to the Office of Information and Regulatory Affairs for another round of regulatory review before issuing the final rule and guidance in the Federal Register.  If the Administration has failed to make significant changes, the final rule will likely be subject to a legal challenge by affected companies and industry trade groups.

On July 16th at the Fairfax Chamber of Commerce offices in Tysons, the Coalition will be launching a new Pricing and Regulatory Compliance Oversight Committee (the PRCO).  Pricing and audit issues are often discussed in the existing committees typically with a focus on existing policies and proposed changes.  For example, we have discussed reform of the Price Reduction Clause (aka the Competition Reduction Clause) in many, if not all, of the committees.  As the name suggests, the PRCO will focus on pricing, regulatory compliance, audits and oversight.  The PRCO will allow the Coalition to better coordinate and leverage our members’ collective domain expertise to support contractor ethics and compliance programs/offices, including in-house counsel, Finance & Accounting, and Compliance departments.

The PRCO will provide a central focal point for monitoring the latest developments in pricing issues and regulatory compliance.  The new committee will be the engine for developing and delivering training, information, analysis and commentary on the compliance issues, challenges and opportunities facing the entire procurement community.  The Coalition will empower the Committee to develop new training to supplement and complement our MAS Basic Training and In-house Counsel courses

As part of this effort we will look forward to a robust Myth-Busters dialogue with the Oversight community in an effort to share best practices around ethics and contract compliance.  The PRCO will meet on at least a quarterly basis and will also support Coalition forums and webinars throughout the year.  For more information and to register for the PRCO, please contact Jason Baccus at JasonBaccus@thecgp.org.

PRCO Training, July 16

Labor Contract Compliances: The World according to the Department of Labor

On the morning of July 16th, the PRCO will kick-off with a training forum “Labor Contract Compliances: the world according to the Department of Labor.”  Among the topics to be discussed at the July 16th training forum will be:

  • The Service Contract Act
    • Contract requirements and disputes
    • Wage determinations
    • Compliance in the MAS contract context
  • The Davis Bacon Act
  • General Labor Compliances (Equal Employment Opportunity and Affirmative Action Plans)
  • The latest in new and proposed regulations, including the proposed Fair Pay and Workplace Safety Executive Order and implementing regulations
  • The Mandatory Disclosure Rule in the context of labor compliance requirements

We are very excited that Jennifer Flickinger and Jeffrey Clayton, Principals at Baker Tilly and Trina Fairley Barlow, Partner at Crowell & Moring LLP, will be our featured instructors for the PRCO Labor Contract Compliances training forum on July 16th. Registration will open next week on the Coalition’s Events page.  Look for more details in next week’s Friday Flash!

On May 28th, the Department of Labor (DOL) published the proposed guidance implementing Executive Order 13673, Fair Pay and Safe Workplaces (the E O).  On the same day, the FAR Council issued a proposed rule that would amend the Federal Acquisition Regulation (FAR) to include new clauses and directives implementing the EO.  Notwithstanding the laudable intentions motivating this regulatory action, the duplicative nature of the EO and it corresponding implementing regime appear to be inconsistent with OFPP’s efforts to improve the procurement system[1] and risk adding duplicative compliance burdens to the procurement system.

The EO requires federal contractors and subcontractors, as part of the proposal submission process, to report whether, during the preceding three-year period, there have been any administrative merits determinations, civil judgements, or arbitral awards or decisions rendered against them for violations of any of 14 identified federal labor laws and executive orders or equivalent state laws.  The reporting requirement continues throughout the life of any subsequent contract.  The EO also establishes a new position, Labor Compliance Advisors (LCAs), at each agency.  Contracting officers will consult with LCAs to assess any reported violations in determining whether a contractor/offeror has a satisfactory record of integrity and business ethics for purposes of the responsibility determination requirement. According to the DOL Guidance, the new labor law compliance reporting requirements will help enhance productivity and the delivery of goods and services to the Federal government in a “timely, predictable and satisfactory manner.”

No reasonable person can object to ensuring compliance with our nation’s labor laws and enhancing productivity in the procurement system.  The connection between the new compliance reporting requirement and improved outcomes in the procurement system, however, is tenuous at best.  The EO, DOL guidance, and proposed FAR rule provide little empirical data supporting the projection of improved procurement outcomes.  In fact, the reporting requirements seem to duplicate the underlying statutes and existing reporting regimes that are the focus of the guidance.  Such duplication adds unnecessary costs to the acquisition system, including the unintended consequence of increasing the amount of funding and resources dedicated to overhead reporting and compliance functions, rather than to direct contract performance.   Equally as problematic, these additional burdens, although costly for all, could weigh more heavily on the small business community.  Ultimately, this regime risks lower efficiency, reduced innovation, and increased costs for government and industry in meeting agency missions on behalf of the American people.

The DOL guidance contains 106 pages and seeks to rationalize and explain the new reporting requirements. Again, it runs counter to the vision enunciated by OFPP, specifically, to improve efficiency, reduce red tape, and provide greater benefit for taxpayers’ dollars.  Instead the DOL guidance:

  • Establishes new reporting requirements for contractors and subcontractors;
  • Includes definitions/terminology relevant to labor laws and unrelated to acquisition—these concepts will have to be understood and applied by both industry and a federal acquisition workforce that is already tasked with implementing complex procurement requirements;
  • Creates a new bureaucracy at an unspecified cost that includes advisors to counsel contracting offices, contractors, and subcontractors on the intricacies of the new rules;
  • Sets forth the prospect of further guidance addressing state law compliance reporting.

The Coalition is concerned that implementation of this guidance will create contract administration issues for commercial item contractors that hold long term IDIQ contracts.  In addition, many questions exist with respect to how various dollar thresholds established by the guidance would be applied and how subcontracting reporting could be rationally implemented.  The Coalition will continue to monitor this guidance on behalf of members.

[1] Administrator Rung specifically recognized, “The overwhelming feedback from industry and other stakeholders is that the complexity of the Federal contracting space leads to higher costs, slower procurements, and less innovation.  Stakeholders cited as problems, among other things, 100 page request for proposals with overly prescriptive, Government-unique requirements, significant contract duplication across Government, and very little sharing of pricing and other contract information between agencies and industry.”  Transforming the Marketplace: Simplifying Federal Procurement to Improve Performance, Drive Innovation, and Increase Savings, Memorandum for Chief Acquisitions Officers and Senior Procurement Executives, Dec. 4, 2014.

Summer Golf Tournament

May 29th, 2015

Get out your golf clubs and start practicing – we are pleased to officially announce that the Coalition’s 3rd Annual Joseph P. Caggiano Memorial Golf Tournament will be held on August 26th at the beautiful Whiskey Creek Golf Club in Ijamsville, MD.  As many of you are aware, this charity tournament is to honor our good friend and colleague, Joe Caggiano, who was not only a 23-year veteran of the federal contracting marketplace but a naval veteran as well.

 

With that in mind, once again, this year’s tournament proceeds will be going to support the Coalition’s endowed scholarship for a qualified veteran concentrating their studies in the field of US Government procurement and pursuing the JD/LLM degree or the interdisciplinary Masters degree at The George Washington University. Joe would be so proud of this scholarship as it encourages the next generation of skilled professionals and veterans to lead this critically important sector of the US economy.  The Coalition created this endowment last year in recognition of our 35th anniversary and we have already collected more than $35,000 by way of your support at last year’s golf tournament and from our silent auction held at our Excellence in Partnership Awards (more on that below!).

 

Please consider a sponsorship for this worthy cause and of course, we encourage you to put a team together as well for this day filled with competition, camaraderie and remembrance.  We have several exciting sponsorships available including title sponsors, luncheon sponsors, beverage cart sponsors, awards/reception sponsors, hole sponsors, and many more with all budgets in mind. Please click here to review sponsorship opportunities and contact Matt Cahill at mcahill@thecgp.org or 202-315-1054 with any questions or commitments.

 

We would like to say a sincere THANK YOU to Integrity Consulting – last year’s tournament winners – for their early commitment to being one of this year’s title sponsors!!  Additionally, Ricoh Americas Corporation proactively reached out already to snag a hole sponsor with foursome.  We appreciate these two companies setting the tone for many more sponsors to follow!

 

Save the date!

 

Lastly, we’d like to have you “save the date” for this year’s Excellence in Partnership (EIP) Awards and Fall Training Conference.  Our EIP’s, complete with silent auction that will further fund the above mentioned endowment, will take place on the evening of Wednesday, October 21st at The Westin Tysons Corner and our Fall Training Conference will take place the following day, Thursday, October 22nd at the same location.  If you are able to donate to this year’s auction (i.e. sports tickets/memorabilia, hotel/travel vouchers, food/wine, etc) please contact Matt Cahill.

A Day of Remembrance

May 22nd, 2015

Memorial Day was originally referred to as Decoration Day and honored those who fell fighting to preserve our Union during the Civil War.  The first official recognition of Memorial Day was on May 5, 1868 when General John Logan, Commander of the Grand Army of the Republic issued General Order No. 11.   The order designated May 30, 1868 as a day “for the purpose of strewing with flowers or otherwise decorating the graves of comrades who died in defense of their country during the late rebellion, and whose bodies now lie in almost every city, village and hamlet church-yard in the land.”  After World War I, Memorial Day became a day of remembrance honoring Americans who have died in any war.  Up until 1972, Memorial Day was celebrated on May 30th each year.  The current three day weekend with Memorial Day falling on the last Monday in May is the result of the National Holiday Act of 1971 (P.L. 90-363) which ensured a three day weekend for Federal holidays.

On Memorial Day, the flag is raised to the top of the staff and then lowered to half-staff.  It remains at half-staff until noon.  The half-staff position is in remembrance of the men and women who died in service to our country.  At noon the flag is raised to full staff and represents our resolve that our honored dead shall not have died in vain but that we will continue to fight for liberty.  At 3 pm on Memorial Day, the “National Moment of Remembrance” calls on the nation to observe a moment of silence or listen to Taps.

I also found two startling statistics:  (1) over one million men and women have fallen in all of America’s wars; and (2) over seven thousand service men and women have fallen since 9/11, and that does not include contractor personnel who support our troops.   It’s always sobering to stop and think that each of the fallen left behind family:  a mother and father, wife or husband, brothers and sisters.  Each loss represents a painful void in a family, a community, a nation.  On May 31, 1982, President Ronald Reagan delivered his Memorial Day speech at Arlington National Cemetery.  These words from President Reagan’s speech sum up Memorial Day for me:

I have no illusions about what little I can add now to the silent testimony of those who gave their lives willingly for their country. Words are even more feeble on this Memorial Day, for the sight before us is that of a strong and good nation that stands in silence and remembers those who were loved and who, in return, loved their countrymen enough to die for them.

Yet we must try to honor them—not for their sakes alone but for our own. And if words cannot repay the debt we owe these men [and women], surely with our actions we must strive to keep faith with them and with the vision that led them to battle and to final sacrifice.

Please make sure you stop and honor our fallen this Memorial Day. God Bless them and keep them and God Bless their families.  God Bless all those in harm’s way defending freedom.  Please also keep those contractor personnel who have fallen while supporting our troops around the world in your thoughts and prayers.

Finally, thank you to all those who serve our country–those in uniform and in civilian service as well as contractor personnel.  We are all in this together.

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