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Friday Flash, 09.21.12

Comment of the Week

This week marks the beginning of a new series of “Comments” highlighting and debunking “Urban Myths” regarding GSA’s Multiple Award Schedule (MAS) program.  Through the Coalition’s “Myth-Busters” conversations with acquisition leadership across the federal government, it has become clear that there are certain “Urban Myths” regarding the MAS program. That’s why we are doing this series.  It is vital to dispel these myths as they stand in the way of the government taking advantage of an outstanding shared services contracting program.

These misperceptions reflect the continuing need to educate customer agencies.  Training on the MAS ordering procedures and e-tools is critical to empowering customer agencies to efficiently and effectively use the MAS program for commercial requirements.  Better understanding means better value for the taxpayer!  Training is a savings investment.  Effective use of the MAS program by customer agencies can save at least 15-20 percent in direct acquisition costs while at the same time reducing unnecessary contract duplication.  And to GSA’s credit, it has invested in both online training and classroom training on effective use of the program.  Information on GSA’s online and classroom training can be found here.

Now let’s address the “Urban Myth” regarding the “high” MAS contract prices.  There are those who criticize MAS contract level prices and point to the additional, significant discounts provided in response to task order competitions for specific agency requirements.   The reality is that the MAS program is designed to provide multiple levels of competition resulting in best value for customer agencies and the taxpayer at the task order level.

First, GSA negotiates MAS contract prices seeking and obtaining discounts from the contractor’s commercial price lists or standard commercial market pricing.  The negotiated, fair and reasonable MAS contract prices are based on contractor’s competitive commercial pricing practices and policies while taking into account differing terms and conditions between the contractor’s commercial contracts and the MAS contract.

Second, each MAS contractor’s prices are posted on GSAAdvantage!, GSA’s electronic catalog, for review, market research and ordering by customer agencies.  This transparent, electronic marketplace is inherently competitive, allowing customer agencies to compare and contrast millions of commercial services and products offered by MAS contractors.  GSAAdvantage! is a dynamic market place.  MAS contractors can and do, post temporary price reductions (special offers) at any time via the website.  Indeed, GSAAdvantage! serves the entire federal market place by providing contracting officers and commercial firms, with a powerful competitive market research tool.

Third, the FAR 8.4 ordering procedures require competition at the task order level.  The new FAR 8.4, as mandated by Section 863 of the FY 2009 National Defense Authorization Act, provides that for MAS orders exceeding $150,000, customer agencies must provide notice and an opportunity to compete to all MAS contractors capable of meeting the requirement.  The contracting officer must also ask for a price reduction for all orders over $150,000.  Alternatively, if notice is not provided to all the contractors, it must be provided as many as practicable to reasonably ensure receipt of at least three quotes.  When the requirement is provided to less than all MAS contractors and less than three quotes are received, before award can be made, the contracting officer must document the file addressing the reasonable efforts to obtain at least three quotes.  The FAR 8.4 ordering procedures ensure robust competition at the task order level in an efficient, streamlined manner that saves customer agencies and contractors time and transactional costs (bid and proposal/administrative).

Fourth, GSA’s e-Buy, the MAS electronic quote tool, provides an efficient and effective channel through which customer agencies can provide notice and opportunity to compete for individual task order requirements.  e-Buy is identified in FAR 8.4 as one method to provide notice to all contractors in accordance with the statutory and regulatory task order competition requirements.

The MAS program’s multiple layers of competition provide customer agencies with a powerful government-wide procurement tool that saves time and money.  That’s why it is vital to invest in education and training.  That’s why we take on the “Urban Myths.”

Roger Waldron



OMB Releases Sequestration Report

The Administration recently released the mandated report on the impact of the automatic sequestration cuts that are set to take effect on January 2, 2013. The report, released in accordance to the Sequestration Transparency Act, includes a detailed breakdown of how 1,200 budget accounts would be impacted by the sequester. This includes what is exempt from sequestration and what is not. According to specifics contained in the report, the automatic cuts will result in a 9.4 percent reduction in non-exempt defense discretionary spending and 8.2 percent in non-defense, non-exempt discretionary spending. Additionally, it would cut 2 percent from Medicare spending, 7.6 percent from other non-exempt non-defense mandatory programs, and 10 percent from non-exempt, mandatory defense programs. Also in the report, the Government asserts its position on sequestration. “As the Administration has made clear, no amount of planning can mitigate the effect of these cuts. Sequestration is a blunt and indiscriminate instrument. It is not the responsible way for our Nation to achieve deficit reduction… It is time for Congress to act.”

In testimony before the House Armed Services Committee, Defense officials explained how the impact of sequestration would affect the Department. In the testimony, DoD issued a stern warning to Congress, stating that “sequestration and the lowering of the discretionary caps would result in a less-capable, less-modern, less-ready force and risks creating a hollow military. It would also require a change in our current national security strategy, which we believe is the right one…We very much hope that Congress will pass a deficit reduction plan that the President can sign and that avoids sequestration.”


UPDATE: Price Reductions Clause Federal Register Notice

On September 20, the General Services Administration posted to the Federal Register a notice of request for comments regarding an extension to an existing OMB clearance for the GSAR’s Price Reductions Clause (PRC). The notice comes in response to comments that were submitted by the Coalition and others concerning the estimated burden and practical utility of the PRC. In the Federal Register GSA notes that, “The Coalition for Government Procurement provided comments on behalf of its members. The comments are insightful and provide a foundation on which to counter-estimate annual burden hours.” Also, “GSA appreciates the comments provided and agrees that the reporting burden was underestimated…Using the results of the contractor survey conducted by the Coalition relative to the burden hours associated with collection of information on the PRC, GSA has reevaluated and revised the total annual burden.” An analysis of the evaluation can be viewed at the link to the notice above. Public comments, due by October 22, 2012, are particularly invited on: Whether this collection of information is necessary and whether it will have practical utility; whether our estimate of the public burden of this collection of information is accurate, and based on valid assumptions and methodology; ways to enhance the quality, utility, and clarity of the information to be collected. The Coalition would like to thank all of our members for their important feedback in developing the survey and our comments to GSA concerning the PRC.


GSA Memo on Preferred Use of Existing Contract Vehicles

The Coalition understands that GSA Acting Administrator Daniel Tangherlini recently issued a memo requiring all employees to use existing GSA acquisition vehicles before establishing new contracts for similar products and services for all contracts exceeding the Simplified Acquisition Threshold of $150,000. This includes: Federal Strategic Sourcing Initiative (FSSI), the Multiple Award Schedules (MAS), Governmentwide Acquisition Contracts (GWACs), and other multiple agency solutions. The Coalition wholeheartedly supports this initiative further encouraging greater use of existing GSA acquisition vehicles, which play a vital role in delivering competition and best value for customer agencies and the American taxpayer.

NEW Proposed Federal IT Acquisition Reform Legislation

Congressman Darrell Issa (R-Calif.) has announced new draft legislation to reform the way federal information technology is purchased. In a NextGov op-ed on September 20, Issa explained that the bill “would give agency CIOs effective budget authority over IT programs and put the CIO Council in charge of developing shared services and shared platforms.” Additionally, it would encourage more federal agencies to adopt cloud solutions, facilitate the use of open source software, “open up federal websites and data for the development of complimentary apps, and support faster data center optimization.” The legislation would create a Federal Commodity IT Center to serve as a hub for coordinated acquisition practices and the management of governmentwide IT contracts. The Coalition will be providing feedback on the draft legislation at the request of the Hill. Chairman Issa has posted a discussion draft of the bill online at the House Oversight Committee’s website. We encourage members to review the draft legislation.


Agencies Increase Contractor Suspensions and Debarments

In a blog post this week, Administrator for Federal Procurement Policy Joe Jordan reported on the results of the Administration’s efforts to increase contractor accountability.  Joe Jordan noted that “while the vast majority of government contractors compete fairly to deliver the best value to the American people, it is critical that the government take a hard line against those who would defraud taxpayers. “  Jordan also referred to a recent report by the Interagency Suspension and Debarment Committee, which stated that agencies have increased suspension and debarments of companies from over 1900 in FY 2009 to more than 3000 in FY 2011.  In addition, since a November 2011 OMB memorandum reminding federal agencies of their responsibility to only do business with contractors of integrity, 24 major executive branch agencies have appointed a senior official to be responsible for the agency’s suspension and debarment program.  These agencies have also increased personnel resources, created new monitoring mechanisms, and simplified the referral process for suspension and debarment.  On these developments, Joe Jordan added that “the ability to debar or ban a certain company from doing business with the U.S. government is an important tool we have to protect taxpayer dollars from waste, fraud and abuse.”


Congressmen Introduce Reform Bill for PBS

On September 20, the House Subcommittee on Economic Development, Public Buildings and Emergency Management approved the Public Buildings Reform Act of 2012 (H.R. 6430). According to a press release posted on Congressman Jeff Denham’s (R-CA) website, the legislation is authored by Transportation and Infrastructure Committee Chairman John L. Mica (R-FL) and Economic Development, Public Buildings and Emergency Management Subcommittee Chairman Jeff Denham (R-CA). Important provisions in the bill include:

  • Requires GSA to offset any request for new space with an equivalent reduction of space through 2016.
  • Requires GSA to reduce its inventory by 1 million square feet per year through 2016.
  • Requires reduction of Public Buildings Service personnel to 2008 levels.

In addition to the three provisions listed, the bill would bolster Congressional oversight of the Public Buildings Service and prohibits bonuses for Senior Executive Service (SES) employees through 2014. For a more comprehensive breakdown of the measures contained in the bill, please link to the press release above.


DoD Memo on Business Base Forecasting

Late last week, director of defense pricing Shay Assad released a memorandum to improve business base forecasting and evaluation, to conduct more accurate forward pricing rate proposals, recommendations and agreements. The evaluation of a contractor’s business base forecast is integral to DCMA’s (Defense Contract Management Agency) ability to successfully negotiate Forward Pricing Rate Agreements and Recommendations, Assad wrote. “Historically, unreliable forecasting of the business base, particularly in the out-years of a contractor’s forward pricing rate proposal (typically years 3-5), has been the leading cause of inaccurate rate proposals, recommendations and agreements. It is also the single leading factor in our inability to reach an agreement on rates with a company.” In the memo Assad goes on to formally request an “increased engagement of each service in the analysis of the business base described in our contractor forward pricing proposals.” To better manage and improve the results Assad asks that each SAE identify an OPR to receive these DCMA requests. For more information please review the original memo at the link above.


Senators Warner and Portman Reintroduce the DATA Act

On September 21, Senators Mark R. Warner (D-VA) and Rob Portman (R-OH) reintroduced the Digital Accountability and Transparency Act (DATA). The legislation requires more standardized reporting of federal spending posted to a single website, allowing citizens and agencies to more easily identify improper payments, waste and fraud.  The measure would also establish the Federal Accountability & Spending Transparency (FAST) Board to track all federal spending including grants, contracts, and loans. The DATA Act was first introduced by Senator Warner in June 2011 and reintroduced today in a revised form with Senator Portman as chief co-sponsor. The House approved its version of the legislation in April.


OASIS Working Group Open to Members

In anticipation of the upcoming OASIS draft RFP and the program’s expected impact within FAS, the Coalition is launching a new working group.  The OASIS Working Group will provide a forum for members to provide input to GSA on OASIS.  If you are a member and are interested in participating, please send an email to Aubrey Woolley at


GSA Announces Upcoming Change to MAS Report Card

In the Fall 2012 issue of GSA Steps, GSA provided an update on the MAS Report Card.  GSA will continue to educate vendors about greenhouse gas (GHG) inventories as part of Contractor Assistance Visits, and plans to remove the GHG question from the MAS Report Card itself.  The following is the article with more details from GSA Steps:

Update on the GHG question on the Report Card

During the past fiscal year, GSA introduced a Report Card question relating to Green House Gases (GHG): “Has the contractor conducted a GHG emissions inventory and established GHG reduction goal(s)?” The intent of this question was to raise awareness of GHG in coordination with initiatives to reduce the federal government’s GHG footprint. In the past months, after listening to industry’s feedback, GSA came to a better understanding of the lack of awareness and information available to you, leading to concern with this question.

In response, by the end of the calendar year, if not sooner, the question on GHG will be removed from the Report Card. As the GHG topic is vital to GSA and the federal government, the opportunity for discussion, awareness, and education will continue during Contractor Assistance Visits. In addition, our focus over the next year will be on developing robust and comprehensive information and resources on the subject, easily accessible to you. As always, it is important that we continue to work together and support each other as business partners.


Registration is Now Open for the 2012 Fall Training Conference!

Join The Coalition on October 24 and 25 for its two day Fall Training Conference, Continuing the Dialogue.  This training conference will address acquisition policy, the federal market and Excellence in Partnership.  Thought leaders from government, industry and academia will give us their perspectives on changes that have occurred and are expected in the federal government’s $200 billion multiple awards contracting program. Contracting officials from all Government-wide Acquisition Contracts (GWACs) and the General Services Administration/Department of Veterans Affairs Multiple Awards Schedules programs will be present to explain their latest initiatives and to participate in break out session to discuss the specifics of their programs.  Hear how sequestration, declining budgets and strategic sourcing may affect what the government buys and how they buy it.

You do not want to miss this training opportunity!

Register here.


Legal Corner 

The Budget Control Act of 2011, Sequestration, and Government Contractors

Jim Schweiter, Partner, McKenna Long & Aldridge LLP

Last August, Congress passed the Budget Control Act of 2011 (“BCA”)(Pub. L. 112-25).  This law authorized raising the debt ceiling, established caps on discretionary spending, and put a process in place to reduce the federal deficit.  The provisions to raise the debt ceiling have been triggered, so that the federal borrowing limit now stands at $16.4 trillion.  In brief, the BCA:

  • Imposed caps on discretionary spending beginning in October 2011 that will generate $917 billion in savings over the next ten years.  The Department of Defense (“DOD”) portion of these savings is approximately $487 billion.
  • Created a bipartisan, bicameral committee to identify up to $1.5 trillion of additional deficit reduction (the Joint Select Committee on Deficit Reduction).  This “Super Committee” failed to reach agreement.
  • Required Congress to vote on a Balanced Budget Amendment to the Constitution.  The amendment failed in both houses.
  • Imposed a budgetary process known as sequestration to implement a total of $1.2 trillion in automatic spending cuts through fiscal year 2021 which will begin January 2, 2013, unless Congress passes a bill which the president signs to avert such a result.

Senior Executive Branch officials, members of Congress and industry leaders all predict catastrophe if sequestration is implemented.  For companies doing business with the federal Government, it is therefore important to understand what sequestration is and how it would operate.  Congress recently passed and President Obama signed the Sequestration Transparency Act of 2012.[1]  Although this law requires the Administration to report to Congress within 30 days about how sequestration would be implemented by federal agencies, few expect this report to provide much useful detail.

Budget Sequestration

Sequestration is a process of automatic, largely across-the-board spending reductions under which budgetary resources are permanently canceled to enforce certain budget policy goals.[2]  This process was first established in the Balanced Budget and Emergency Deficit Control Act of 1985 (BBEDCA).[3]  Sequestration involves the permanent cancellation of budgetary resources by a uniform percentage, which is applied to all non-exempt programs, projects and activities within a budget account[4] in order to achieve required savings.

Under the BCA, there are two situations in which sequestration could occur—

  • If Congress appropriates more money in any year than is allowed under the annual discretionary spending limits established in the BCA, the automatic process of sequestration would result in the cancellation of the excess amount.  The President would issue an order canceling any excess budget authority.
  • Because Congress failed to enact legislation developed by the Joint Select Committee on Deficit Reduction to reduce the deficit by at least $1.2 trillion by January 15, 2012, the BCA provides for a series of automatic spending reductions in both discretionary and direct (mandatory) spending[5] to make up for the shortfall in savings.

Sequestration is thus a budget enforcement mechanism that is intended to prevent enactment of legislation that would increase the federal deficit.  Under the BCA, the automatic sequestration procedures will affect both mandatory and discretionary spending programs, and the reductions will affect defense and non-defense spending categories equally in each of fiscal years 2013 through 2021.

Under the BCA, the Department of Defense (DoD) would have to absorb half the cuts required by sequestration, a total of $492 billion.  Non-defense accounts would absorb an equal share. Because the cut would be spread over nine years (2013-2021), both the defense and non-defense portions of the federal budget would be subject to annual reductions of about $54.7 billion.[6]

Implementation of Sequestration

The process by which sequestration would be implemented is different in 2013 than in 2014 and the out years.  In 2013, there would be across-the-board, proportional reductions in programs, projects and activities funded by annual appropriations and in non-exempt mandatory programs.[7]  In 2014 through 2021, the required sequestration cuts would be achieved by reducing the statutory spending limit specified in the law for each year.  How this “top line” cut would be implemented at the agency level would be governed by the appropriations process.   The Office of Management and Budget would direct agencies to implement cuts to available appropriations based on apportionment guidance issued pursuant to OMB Circular A-11.[8]

Sequestration would not begin until January 2, 2013, so the funding reductions would be spread over only three quarters of that fiscal year.  Appropriated funds that have been obligated to contracts are not subject to the sequestration process.  Appropriated fund balances that remain unobligated as of January 2, 2013 may be subject to sequestration.  If, as now appears likely, the federal government will be funded by continuing appropriations resolution (a “CR”)[9] during the first half of fiscal year 2013,[10] the ability of agencies to enter into new contracts, issue new task orders on existing multiple award contracts or exercise contract options that would obligate funds before sequestration begins will be constrained.  Guidance from OMB also could limit agency spending in advance of sequestration.  Because the baseline for fiscal year 2013 funding has not been established, and because there are so many variables that may affect how sequestration would be implemented, contractors of all stripes must closely examine their contracts and funding status in making judgments about how to prepare for sequestration.


“The president [and] the secretary of Defense said it would be catastrophic to our national defense, but we still haven’t found a way through it,”  Arizona Senator John McCain said recently about sequestration. “Everybody says it’s not going to happen, but so far, it’s going to happen.”[11]  If the worst occurs, it is imperative to understand the magnitude of the funding cuts that would occur if sequestration as provided in the Budget Control Act is implemented and for contractors to plan accordingly.


[1] H.R. 5872 was signed into law by President Obama on August 7, 2012.

[2] OMB Circular A-11, sec. 20, at 8 (Aug. 2011); see also 2 USC 900(c)(2).

[3] Title II of Pub. L. 99-177, sometimes referred to as the Gramm, Rudman, Hollings Act.

[4] See 2 USC 906(k)(2); Under the BCA, many mandatory spending programs would be exempt from sequestration cuts, including Social Security, other federal retirement programs, Medicaid, and other programs benefiting low-income people.  Medicare cuts would be limited to no more than two percent.  See sections 255 and 256 of the BBEDCA (codified at 2 USC 905, 906).

[5] “Discretionary spending” refers to outlays from budget authority that is provided and controlled

by appropriation acts. “Mandatory spending” refers to outlays from budget authority that is provided

by laws other than appropriation acts.  Congressional Budget Office, Estimated Impact of Automatic Budget Enforcement Procedures Specified in the Budget Control Act, n. 2, at 1 (Sept. 12, 2011).

[6] For the mechanics of the calculations, see BBEDCA sec. 251A(3), as added by BCA, Pub. L. 112-25, sec. 302(a), (Aug. 2, 2011).

[7] The Budget Control Act provides that certain programs are exempt from sequestration funding cuts.  These include Social Security, Medicaid, certain Medicare payments, federal retired pay, and VA programs.  In addition, the White House recently announced that the President has decided to exempt the military personnel accounts from sequestration, although this will mean a proportional increase in the size of the cuts to other non-exempt defense accounts in order to achieve the required level of deficit reduction.

[8] See OMB Circular A-11, Part 4, sec. 120.1 et. seq. (Nov. 2011).  As of this writing, OMB has not yet issued apportionment guidance to federal agencies regarding sequestration.

[9] A continuing resolution is “an appropriation act that provides budget authority for federal agencies to continue in operation when Congress and the President have not completed action on regular appropriation acts by the beginning of the fiscal year.”  Government Accountability Office (GAO), A Glossary of Terms Used in the Federal Budget Process, GAO-05-734SP, September 2005, pp. 35-36.

[10]  See, Rosalind S. Helderman, John Boehner, Harry Reid Reach Early Deal to Avert Shutdown,  Wash. Post, July 31, 2012, at

[11] Nancy Cook, High Anxiety, National Journal, June 30, 2012.


Members are Invited to Hear From Kathleen Turco

Kathleen Turco, GSA Associate Administrator for Governmentwide Policy will join the Coalitions’ Federal Buildings Committee to discuss the government’s telework policies which cover topics such as security, emergency planning, and reduction of overhead and labor costs. The meeting will be held at 10:00am on Thursday September 27 at the office of Mayer Brown LLP, 1999 K Street Northwest Washington, DC 20006. If you would like to attend this meeting, please RSVP to Space is limited.


Accepting EIP Award Nominations

The EIP Awards honor acquisition officials who have made significant strides in promoting and utilizing multiple award contracting vehicles. Awards will be given to individuals, organizations and contractors involved in procurement with GSA, VA, DHS, DoD and other government agencies. Take this opportunity to recognize an individual or organization that is deserving of an EIP Award. A list of nomination categories along with links to submit your nominations can be found here. Nominations along with a short rationale of approx. 100 words is sufficient. Nominations will be accepted through October 1. If you have any trouble with the system, please email

Contractor Savings Award

Presented to a contractor for developing significant innovative solutions resulting in savings to the government and taxpayer through sound acquisition planning and development, and well defined contracting requirements.

Government Savings Award (Civilian)

Presented to a government agency, entity or individual for developing significant innovative solutions resulting in savings to the government and taxpayer through sound acquisition planning and development, and well defined contracting requirements.

Government Savings Award (DoD)

Presented to a government agency, entity or individual for developing significant innovative solutions resulting in savings to the government and taxpayer through sound acquisition planning and development, and well defined contracting requirements.

Myth-Busters Award (Civilian)

Presented to an individual or office for facilitating open communication between government and industry during the acquisition process and effectively breaking down communication barriers to create a collaborative procurement environment.

Myth-Busters Award (DoD)

Presented to an individual or office for facilitating open communication between government and industry during the acquisition process and effectively breaking down communication barriers to create a collaborative procurement environment.

Lifetime Acquisition Excellence Award

Presented to an individual in the procurement community for delivering best-value solutions for the taxpayer and has demonstrated a long-term commitment to improving the federal acquisition system.

Best Veteran Hiring Program (Government)

Presented to a government agency for promoting and executing a robust and successful veteran hiring program to the benefit of our brave men and women in uniform.

Best Veteran Hiring Program (Industry)

Presented to a government contractor for promoting and executing a robust and successful veteran hiring, teaming or subcontracting program to the benefit of our brave men and women in uniform.

2012 EIP Award Winners will be honored during the Coalition’s upcoming Fall Conference on October 24th and 25th at the Crystal Gateway Marriott.


Advanced MAS Training Announced

The Coalition for Government Procurement presents the Advanced MAS Training program for experienced professionals and in-house counsel with significant responsibility for MAS contracts.  Join our panel of experienced practitioners for an interactive discussion based on a hypothetical scenario that presents many of the common wrinkles in MAS contracting.  Our panelists will address the current critical issues for MAS contractors and provide practical advice regarding the major challenges in MAS contracting.

Among other topics, our panelists, David Dowd from Mayer Brown and Jason Workmaster from McKenna Long & Aldridge will address:

  • Pricing – CSP:  Getting your pricing disclosure correct as well as Price Reduction Clause compliance
  • Audits – Laying the groundwork for an audit and surviving the process
  • Pitfalls and Problems – Mandatory DisclosuresFalse Claims Act – Risks and Consequences

Registration – Coming Soon!


Small Business Forum & New CGP Committee

Small Business Forum – New Strategies for a Changing Environment

As you know, increased small business utilization is a high a priority of the Federal Government.  Regulatory, legislative and agency level changes are all possible.  On October 30th, the Coalition will host a small business forum to gain insight from senior government officials on significant changes to the small business rules and how they impact your strategies for selling to federal agencies.  A panel of small and large businesses will discuss their current and changing experiences.

A. John Shoraka, Associate Administrator of Government Contracting and Business Development, SBA will discuss small business priorities and regulatory changes including the proposed rule implementing set asides on multiple award contracts.

A panel of successful small and large businesses will examine the topic Small and Large Business Collaboration in the Federal Market – What Works and Doesn’t Work

Panel Moderator – Joseph Hornyak, Partner, Holland and Knight

James Connal, Vice President, Red River Computer

Tom Walker, Government Manager, Nucraft Furniture

Wayne Pizer, Vice President, L-3 National Security Solutions

Who Should Attend:

  • Small Businesses that sell or  want to Federal Agencies
  • Large businesses that team with, subcontracts to or sells indirectly through small business concerns
  • Federal Buying Official

Keystone Member: Invited
Premier Member: $65
Regular Member: $75
Non-Member: $130
Government: $15


Upcoming Regulatory Comments

The Coalition regularly provides public comments on rules that impact the membership.  The following is a list of upcoming rules.  We ask that members note the proposed rule on Basic Safeguarding of Contractor Information Systems which was published in the Federal Register last week.  The Coalition plans to submit comments on this proposed rule and will provide further analysis on it in an upcoming edition of the Friday Flash.

Federal Acquisition Regulation; Basic Safeguarding of Contractor Information Systems

Proposed Rule       

Summary: DoD, GSA, and NASA are proposing to amend the FAR to add a new subpart and contract clause for the basic safeguarding of contractor information systems that contain information provided by or generated for the Government that will be resident on or transiting through contractor information systems.

Due October 23, 2012.  If you have any comments regarding this proposed rule, please contact Aubrey Woolley.

Federal Acquisition Regulation; Prioritizing Sources of Supplies and Services for Use by the Government

Proposed Rule

Summary: On September 6, a proposed rule was published to the Federal Register that corrects the preamble to a proposed rule published in the Federal Register of June 14, 2011, regarding Prioritizing Sources of Supplies and Services for Use by the Government.This document adds an Initial Regulatory Flexibility Analysis which has been determined to be necessary since the initial publication of the proposed rule. As first published, the rule amends FAR part 8, which requires Federal agencies to satisfy their requirements for supplies and services from or through a list of sources in order of priority.

Due October 9, 2012. If you have any comments regarding this proposed rule, please contact Aubrey Woolley.

Revision of Department of Homeland Security Acquisition Regulation; Contractor Billing and Subcontractor Labor Hour Rates Under Time and Materials Contracts

Notice of Proposed Rulemaking            

Summary: DHS is proposing to amend its Homeland Security Acquisition Regulation to require contracts for time and material or labor hours to include separate labor hour rates for subcontractors and a description of the method that will be used to record and bill for labor hours for both contractors and subcontractors.

Due October 22, 2012.  Please contact Carolyn Alston if you would like to contribute to the Coalition’s comments on this issue.

Department of Treasury Acquisition Regulations; Contract Clause on Minority and Women Inclusion in Contractor Workforce

Notice of Proposed Rulemaking

Summary: The Department of the Treasury is proposing to amend the Department of the Treasury Acquisition Regulation (DTAR) to include a contract clause on minority and women inclusion, as required by the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 (the Dodd-Frank Act).

Due October 22, 2012.  Please contact Carolyn Alston if you have any feedback on this notice.



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