FAR and Beyond Blog
Wednesday night brought 14 inches of snow to Northern Virginia—significantly more than predicted! (Gee, how did that happen?) I spent Thursday morning shoveling the driveway and sidewalk. Everything is closed. The streets are not plowed. It is Washington, DC. Enough already! It is time for Olde Man Winter to retire! And with the venting done, let’s turn to this week’s comment.
Earlier on Wednesday the Department of Defense (DoD) issued a request for public comment as part of the Director of Defense Procurement and Acquisition Policy’s (DPAP’s) “assessment to identify impacts experienced by industry resulting from contracting statutes.” The Federal Register notice can be found here. DPAP has identified approximately 400 DFARS requirements based solely on statute. As part of the assessment, the DPAP Director is seeking public input with regard to—
- Particular impacts associated with specific contracting statutes;
- Why the identified impact does not achieve the intended benefit of the identified legislation, or why the identified benefit is not helpful to the Department; and
- Any recommendations for alternative approaches to achieve the intended benefit of the identified legislation.
The notice also states that DPAP is interested in feedback on DFARS provisions that are not based on statute, but warrant similar consideration. Public comments are due March 14th.
DPAP’s request presents a wonderful opportunity to provide information/data regarding statutory requirements where the costs outweigh the benefits. Just as important, the public should use this opportunity to also address the benefits of certain statutes. In particular, the benefits of the current statutory definition of “commercial item” far outweigh perceived costs. With the budget challenges facing the federal government, innovation can drive savings, efficiency and effectiveness. The flexibility provided by the “of a type” definition enhances competition and expands the commercial market across the federal enterprise. Simply put, the commercial item definition facilitates access to new technologies, solutions and services. We cannot afford to restrict it.
Our first comment in response to the notice will be a recommendation to extend the due date for comment to May 14th. Given the importance of the task combined with the extensive number of statutory requirements to review, additional time is needed for the public to respond with fulsome, sound comments for consideration by the Secretary of Defense..
Finally, the Coalition will be responding to the request for comment. We will be providing our members with the 400 statutory cites with the corresponding DFARS reference as compiled by DPAP. We look forward to your feedback. Next week we will be seeking volunteers for a working group to develop consensus comments for submission to DPAP.
President Obama released an Executive Order this week setting a minimum wage for Federal contractors. The minimum wage is $10.10 and will apply to contracts issued on or after January 1, 2015. Annually thereafter, the minimum wage will be increased based on the Consumer Price Index for Urban Wage Earners and Clerical Workers. Though the requirement is not effective until 2015, contractors may see the requirement in new contracts this year. The executive order encourages Federal agencies to begin implementing the minimum wage as “reasonable and legally permissible” in all new contracts negotiated between February 12, 2014 and January 1, 2015.
Covered contracts (and contract-like instruments) listed in the Executive Order are:
- Procurement contracts for services and construction
- Contracts for services covered by the Service Contract Act
- Contracts for concessions
- Contracts related to Federal property or lands offering services for Federal employees, their dependents, or the general public.
The $10.10 minimum wage also applies to subcontracts. The Department of Labor will issue regulations implementing the executive order by October 1, 2014. The FAR Council will issue changes to the Federal Acquisition Regulation 60 days thereafter. Compliance with the minimum wage requirement will be monitored by the Labor Department.
GSA announced this week that it has exceeded its commitment to energy savings performance contracts (ESPCs) by $16 million. Since the President’s Better Buildings Challenge was established in 2011, GSA has awarded more than $191 million in ESPCs to improve the energy performance of Federal buildings. GSA has entered nearly 100 Federal buildings into ESPCs. Under ESPCs, the government can take advantage of energy savings innovations from the private sector with no up-front costs to taxpayers.
Under the President’s Climate Action Plan, GSA is furthering its commitment to ESPCs again to help the government meet its new savings objectives by 2016. According to a blog post by Kevin Kampschroer of GSA’s Office of Federal High Performance Green Buildings, GSA estimates that they can achieve approximately $10.6 million in annual savings from energy and water reductions.
On February 12, the National Institute of Standards and Technology (NIST) released the inaugural version of its Framework for Improving Critical Infrastructure Cybersecurity. According to a press release, the framework provides a structure that organizations, regulators and customers can use to create, guide, assess or improve comprehensive cybersecurity programs. In addition to the framework, NIST released a “Roadmap” document, to explain future versions of the framework, and ways to address cybersecurity development, alignment and collaboration. The document was released in accordance with Executive Order 13636: Improving Critical Infrastructure Cybersecurity. The framework contains three components: the core, profiles and tiers. The components are as follows:
- The Framework Core is a set of cybersecurity activities and informative references that are common across critical infrastructure sectors. The cybersecurity activities are grouped by five functions — Identify, Protect, Detect, Respond, Recover — that provide a high-level view of an organization’s management of cyber risks.
- The Profiles can help organizations align their cybersecurity activities with business requirements, risk tolerances, and resources. Companies can use the Profiles to understand their current cybersecurity state, support prioritization, and to measure progress.
- The Tiers provide a tool for organizations to view their approach and processes for managing cyber risk. The Tiers range from 1-4 and describe an increasing degree of rigor in risk management practices.
Member Feedback Requested on ODCs
The General Services Administration (GSA) recently released a request for information (RFI) on Other Direct Costs (ODCs). The Coalition has drafted a response to the RFI. Members please review the draft and provide any suggestions to Carolyn Alston at email@example.com by February 24, 2014.
We are also asking members to complete a 5 minute survey on ODCs so that we can provide more details in our response.
ODC Member Survey
The survey will be open through Monday February 24, 2014. Thank you in advance for your submissions!
Officials in the Homeland Security Department’s Immigration and Customs Enforcement (ICE) directorate said they are taking the $64 million TECS program in a different direction, according to Federal News Radio. The effort to modernize TECS has been halted after federal auditors discovered problems with both ICE and Customs and Border Protection (CBP) acquisitions. ICE’s case management designs were not technically viable. The agency said in a hearing last Thursday it’s pivoting from custom-built software to a commercial-off-the shelf approach. “We learned when we went out to do market research is that the market has changed and that there are commercial, off-the-shelf programs that we can now use.” On Wednesday, a request for information for industry was released on FedBizOpps.gov. ICE wants to make a new award by June 2014, and both CBP and ICE say they still believe they can leave their 1980s mainframe system behind by 2015.
The Coalition’s Green Committee will hear from the EPA February 25 to learn more about their plans to develop guidelines for Federal agencies to follow when using Ecolabels in Federal procurement. Specifically, we will be discussing the EPA’s recent Ecolabels notice in the Federal Register. The EPA has extended the deadline to respond to April 25, 2014.
The Green Committee’s meeting with the EPA will be on Tuesday, February 25 at 10am in Washington, DC at 3M Government Markets. GSA will also have a representative participate in the discussion. This is a great opportunity for a Myth-buster’s dialogue on green procurement! For more details and to register, please contact Aubrey Woolley at firstname.lastname@example.org.
By: Jack Horan, Partner, McKenna Long & Aldridge LLP
Effective and compliant contract administration should be a primary goal for all government contractors, including, of course, contractors with the Department of Veterans Affairs (VA). As with any other business goal, compliance should be attained efficiently. Within the web of statutory, regulatory, and contractual requirements, VA contractors should understand the areas where noncompliance creates the greatest risk and exposure, and spend their resources accordingly.
As with the Offices of Inspectors General throughout the government, the VA Office of Inspector General (OIG) is a central player in the oversight of contracts, enforcing compliance with all major VA statutory, regulatory, and contractual requirements, and redressing compliance failures. As part of its responsibilities, the VA OIG reports to Congress twice annually on the audits, reviews, and investigations it conducts. Although intended for other purposes, these reports can assist VA contractors in identifying the requirements that are of the most importance to the VA, and should be most important to the contractor. In short, VA OIG’s actions over the prior year serve as a lesson to contractors on where to spend their time and money (and the effect of noncompliance).
The VA OIG has “a nationwide staff of auditors, investigators, health care inspectors, and support personnel” in six major component “offices” that conduct “independent oversight reviews to improve the economy, efficiency, and effectiveness of VA programs, and to prevent and detect criminal activity, waste, abuse, and fraud.” For a VA contractor, the three component offices that are of most importance are: (1) the Immediate Office of the IG; (2) the Office of Counselor to the IG; and (3) Office of Investigations.
The Immediate Office of the IG is top-tier management, with the Deputy Inspector General operating as the “Chief Operating Officer.” In addition to planning, directing and monitoring all [IG] operations,” the Immediate Office establishes investigative priorities for the Office, and identifies and promotes legislative initiatives to Congress.
The new year should bring a new IG to the VA. On November 6, 2013, GeorgeOpfer announced his retirement as IG after more than 44 years of government service. Mr.Opfer assumed responsibility as Inspector General on November 17, 2005, after being nominated by President GeorgeW.Bush. Although President Obama has not nominated a replacement, Mr.Opfer’s long-time Deputy, RichardGriffin, is currently serving as Acting Inspector General. Mr.Griffin has been a Deputy Inspector General since November 23, 2008, and previously served as Inspector General from November 1997 to June 2005.
A change in Inspector General can have a significant effect on the priorities, policies, and procedures of an office – as demonstrated by the GSA’s OIG under the direction of the current IG, Brian Miller. Given his status as Acting Inspector General and his long service under Mr.Opfer, it would be surprising if Mr.Griffin made dramatic changes to the VA OIG’s policies or procedures. Significant changes will likely come, if at all, under the next IG.
The Office of Counselor provides counsel to the OIG on False Claims Act cases affecting the VA and serves as liaison to the Department of Justice on False Claims Act cases. The Office of Counselor also manages the Office of Contract Review, which provides pre-award and post-award audits of contractors’ proposals and contracts under an agreement with VA’s Office of Acquisition, Logistics and Construction (OALC). The majority of pre-award audits of proposals for contracts or modifications under the VA’s Federal Supply Schedule (FSS) program. The Office automatically reviews the pricing for all proposals when the estimated contract or modification exceeds $5,000,000 under Schedule 65IB, Drugs, Pharmaceuticals, and Hematology Related Products, and $3,000,000 for the other VA Schedules. The Office of Contract Review also reviews pharmaceutical manufacturers’ compliance with the pricing requirements of the Veterans Health Care Act. Thus, the Office of Contract Review reviews pricing for major VA contracts and ensures the pricing is compliant with contractual, regulatory, and statutory requirements, and provides a recommendation to the contracting officer on the prices the VA should pay for items on large FSS contracts.
So how did the pricing proposed by potential contractors fare with Office of Contract Review? During fiscal year 2013, the Office conducted 83 pre-award audits of proposals of all types, and identified $655,056,285 in cost savings, or an average of $7.9 million in cost savings per audit. It’s safe to say that the Office did not routinely accept pricing as proposed by the contractors.
How about proposals for FSS awards, renewals or modifications? Forty-six of the 83 pre-award audits were of proposals for awards, renewals or modifications under the FSS program – 32 for initial award, ten for renewals, and four for modifications to add products. The Office recommended a price reduction for 72% (23 of 32) of the audited proposals for initial award. The Office recommended a total of $470,428,110 in price reductions, with an average of $14.7 million per audit (including all 32 audits). Thus, offerors submitting proposals for an initial award of an FSS contract fared worse than the average contractor subject to pre-award audits.
With pricing established by the existing contracts, one would expect that the contractor would fare better in pre-award audits for contract renewals. Contractors did fare better but the Office frequently challenged the proposed pricing. The Office recommended a total of $18,577,827 in price reductions, with an average of $1,857,783 per audit. The OIG recommended a price reduction for 60% (six of ten) renewal proposals.
Contractors seeking product additions fared the best over the past year with the OIG recommending price reductions in only 25% (one of four) of its audits. The one price reduction was a significant one though — $8,615,256.
So, here are the lessons learned from the pre-award audits:
- Most obviously, the OIG takes a hard look at proposed pricing, in the past year rejecting 72% of pricing proposed for initial award, 60% for renewals, and 25% for modifications.
- A contractor needs to be prepared to support its pricing not only when it is seeking the initial FSS contract, but also at renewal and for each modification.
Now let’s look at post award audits – audits conducted to determine whether a contractor is complying with its pricing obligations. The Office reported 33 post-award audits in fiscal year 2013, which resulted in the VA recovering contract overcharges totaling over $17.6 million. According to the OIG, approximately $11.7 million of that recovery resulted from Veterans Health Care Act compliance with pricing requirements, recalculation of Federal ceiling prices, and appropriate classification of pharmaceutical products.
Fourteen of the post-award audits were of voluntary disclosures. The Office claimed more than offered by the contractor in nine of 14 voluntary disclosures. The average recovery to the VA from voluntary disclosures was $1,157,117.
The VA recovered 100 percent of recommended recoveries for post-award audits.
Lessons learned from post-award audits:
- Pay close attention to your Veterans Health Care Act pricing – it is a major compliance area for the OIG, comprising the largest recovery area.
- Be prepared to support your accounting and rationale for any voluntary disclosures. The disclosure is likely to be audited and the proposed repayment amount is likely to be challenged.
- Your opportunity to affect the government’s view of your liability is through negotiations with the OIG. The Office has an excellent record – 100% of the time – of recovering what it determines the VA is due.
Now, a look at the focus of the Office of Investigations over the past fiscal year. The Office of Investigations (OI) investigates crimes committed against programs and operations of the VA. Within the OI, the Criminal Investigations division investigates all types of crimes (including criminal fraud as well as rape and murder) and civil fraud. For fiscal year 2013, the OI reported opening 45 cases, making 11 arrests, and obtaining more than $564.1 million in fines, restitution, penalties, and civil judgments “in the area of procurement practices.”
The OI specifically identified twelve criminal cases involving procurement violations by contractors – all twelve involved service-disabled, veteran-owned small business fraud. In those cases, the SDVOSB business either misrepresented the eligibility of its owner, or the true ownership of the business.
Lessons learned from the OI:
- Exposure under the False Claims Act for VA contracts can be very significant – reaching over $500 million in 2013.
- People get arrested and go to jail for defrauding the VA.
- If you tell the VA that you are a serviced-disabled veteran and own and operate a SDVOSB, you better be a service-disabled veteran and own and operate the SDVOSB.
Finally, one other lesson learned – this one from the structure of the VA OIG. Contact by the Office of Contract Review and the Office of Investigations can both lead to civil or even criminal liability, but there is a significant difference. If the contact comes from the Office of Investigations, the issue has already likely been determined to be a potential civil fraud or criminal violation. There is no doubt that it is time to call your lawyer.
 See Semiannual Report to Congress, Issue 69, (October 1, 2012 – March 31, 2013),VA OIG; Semiannual Report to Congress, Issue 70 (April 1 – September 30, 2013), VA OIG.
 The three other component offices are the following: (1) the Office of Audits and Evaluations, which audits and evaluates the effectiveness of the Veterans Health Administration programs and Veterans Benefits Administration programs; (2) the Office of Healthcare Inspections, which monitors the healthcare provided to the veterans; and (3) the Office of Management and Administration, which provides comprehensive support services to the VA OIG, and administers the VA OIG Hotline.
 The Office of Counselor also supervises the Release of Information Office, which primarily processes Freedom of Information Act and Privacy Act requests for OIG records, as well as other requests for information.
 The reports describe the pre-award audits results as “potential cost savings” and “savings and cost avoidance” so it is not clear whether these amounts include audit recommendations ultimately rejected by the contractors.
 To provide some perspective, the VA estimates that there are currently 1900 contract holders under its FSS program.
 The categorization of the pre-award and post-award audits in this article are based on the description of the audits in Appendix A of the reports.
 The OIG’s reports labeled eleven post-award reviews as involving voluntary disclosures with a total recovery to the VA of $12,728,288.
 This amount includes a $500 million fine resulting from a False Claims Act case against a large pharmaceutical company.
Reporting Potential Fraud to the U.S. General Services Administration Office of Inspector General
By: Brian Miller, Inspector General , U.S. General Services Administration
The mandatory disclosure rule contained in the Federal Acquisition Regulation has now been in effect for slightly more than five years. Under the rule, federal contractors are required to report potential fraud and false claims related to their contracts to the Office of Inspector General (OIG). We believe implementation of the rule at the General Services Administration (GSA) has been successful, but we also believe more can be done. In this article, we outline the GSA OIG disclosure program, why contractors should make disclosures, and some best practices for contractors that we have noted.
The GSA OIG Disclosure Program
When the mandatory disclosure rule was made final at the end of 2008, the GSA OIG implemented a program to process contractor reports. My office has received over 120 disclosures and recovered almost $15 million under this program so far.
When the GSA OIG receives a disclosure, we provide a copy to the responsible contracting officer and the Department of Justice (DOJ), and we notify the OIGs of other affected agencies. We regularly coordinate with the Department of Defense (DOD) OIG since a significant number of disclosures involve both GSA and DOD (for example, an affected DOD program purchased goods or services through a GSA schedule contract).
We make an effort to keep contractors up-to-date on the status of the disclosure, starting with an acknowledgement letter after receipt of a disclosure and an initial in-person meeting to talk about details of the reported conduct. After the meeting, we request further details as necessary to better understand the nature of the conduct or verify the amount owed the government. These requests may include documentation of facts and figures, explanations of calculation methods, or interviews of company employees who can explain how problems occurred and any mitigating factors that will prevent future problems. As explained below, we have noticed some best practices by contractors that we suggest all should follow.
Why it’s a Good Idea to Make Disclosures
While we are encouraged by the number of contractors making disclosures, we believe that more should do so. It is in the contractor’s own interest to disclose. Making disclosures is legally required and making a disclosure by itself will not result in suspension or debarment. However, a failure to disclose can lead to suspension or debarment. In addition, a good-faith disclosure and full cooperation can go a long way toward demonstrating a contractor’s integrity and present responsibility, and should be in compliance with the contractor’s ethics program. In this regard, my office has not referred any contractor that has made a disclosure to GSA’s suspension and debarment official, and only in two unique instances has my office referred a disclosure to DOJ.
Another reason for making a disclosure to the OIG is that it gives a contractor an opportunity to do an internal investigation and to present its side of the story to the OIG, without being distracted by litigation or in the middle of an OIG investigation or audit. We suggest that contractors are better off disclosing before we begin an investigation or audit. After contacting us, we prefer that the contractor do an internal review, as long as we are informed as the internal review progresses.
We recognize that a few contractors may hope that their conduct is never discovered and they are never held accountable for their actions. In today’s world, however, that belief may be unrealistic. We live in a world where most things come to light in one way or another. Contractors may choose to balance the risk of getting caught against the potential penalties, but in our view that balance is clear: reporting produces benefits that outweigh the risks — besides it being the right thing to do.
Best Practices When Making Disclosures
During the course of processing disclosures, we have seen some contractor practices that are particularly helpful in resolving disclosures efficiently, and we are hopeful that all contractors will:
1) provide timely and thoroughly documented factual information with the initial disclosure (or in an update to the disclosure as soon as an internal investigation is complete);
2) include a description of the conduct that occurred, an explanation of the date range, how the conduct was discovered, its consequences, remedial action taken, an assessment of the amount owed to the government, and an explanation of how the amount was calculated, including any legal conclusions used for the calculation;
3) identify relevant issues and witnesses;
4) keep the OIG informed on the progress of an internal investigation and the collection of additional materials and information; and
5) err on the side of over-communicating.
Of course, contractors have amassed experience during the past five years of the disclosure program as well, and we are interested in hearing your lessons and suggestions.
 Contractor Business Ethics Compliance Program and Disclosure Requirements, 73 Fed. Reg. at 67,064, 67,066 (Nov. 12, 2008).
DoD Seeking Feedback on DFARS
Defense Procurement and Acquisition Policy (DPAP) is requesting comments on the impact of certain DFARS requirements on industry. They are currently conducting an assessment of these impacts as part of a broader effort to reduce compliance burdens. Comments are due March 14, 2014. To access DPAP’s request for comments in the Federal Register, click here.
As described in the FAR and Beyond blog above, the Coalition will submit comments. First we will request that the comment period be extended to May 14, 2014 in order to provide substantive recommendations and feedback to the Department of Defense. The Coalition will also have a working group to formulate our comments. Members interested in participating, please contact Roy Dicharry at email@example.com.
OPM Cancels $2 Billion Solicitation
The Office of Personnel Management (OPM) has cancelled a solicitation for its $2 billion Customized Human Resources Solutions Services (CHRS) initiative. According to a report from Federal News Radio, an OPM official said the solicitation was cancelled due to the changing requirements of the government. “OPM has determined it is necessary to redefine the requirement to align the capabilities of the resultant contract with the evolution of both government-wide and OPM strategic goals, strategic sourcing considerations, current budgetary realities across government and to better support the mission of the federal agencies that OPM serves and deliver better service to the American public,” the official explained. OPM now plans to prepare and finalize revised requirements, the solicitation structure, and a formal business case. Intended as an update to the Training and Management Assistance contract, CHRS would have provided customized training/learning and human capital solutions, reports ASI Government.
GSA Closes 24 Data Centers
Federal Times reports that the General Services Administration (GSA) will be closing 24 data centers in fiscal year 2014, according to Acting Chief Information Officer Sonny Hashmi. In fiscal year 2013, GSA closed 37 data centers in accordance with the Federal Data Center Consolidation initiative. According to Federal Times, the Office of Management and Budget (OMB) has publicized data center consolidation as a major cost-cutting initiative, estimated to save $3 billion by 2015.
DPAP Extends Deadline for IR&D
Defense Procurement and Acquisition Policy (DPAP) director Richard Ginman has released a memorandum extending the deadline for contractor reporting of independent research and development (IR&D) projects. A final rule effective January 30, 2012, provided that a major contractor’s annual IR&D costs are allowable only when the contractor reports project information to the Defense Technical Information Center, with updates at least annually and upon project completion. The extension comes as some contractors have indicated confusion regarding submittal timeframes. According to the memo, administrative contracting officers (ACOs) should use the project summaries submitted to the Defense Innovation Marketplace to determine whether IR&D projects are of potential interest to the Department of Defense. In addition, ACOs should communicate with affected contractors about adequately supporting reported IR&D costs, including:
- Entering projects generating IR&D costs into the Defense Innovation Marketplace no later than three months after the end of the contractor fiscal year (CFY) in which costs initially were incurred
- Updating summaries for ongoing projects no later than three months after the end of each CFY
- Submitting a final summary for each completed project; IR&D costs are unallowable if the related project information is not reported or updated within three months after the end of the CFY in which the costs were incurred.
General Services Administration’s Integrated Technology Service’s Priorities for 2014
February 20, 7:30am, Tower Club, Tysons, VA
Come hear Mary Davie and Mark Day talk about FAS ITS’s goals and initiatives for 2014 that will help drive innovation, streamline acquisitions, and drive down the cost of innovative IT for government. Initiatives like FSSI Large Publisher, Network Services 2020, Alliant and Alliant SB II, improvements to Schedule 70 and more will be discussed.
Mary Davie, Assistant Commissioner of GSA’s Office of Integrated Technology Services (ITS)
Mark Day, Deputy Assistant Commissioner of GSA’s Office of Integrated Technology Services (ITS)
The Coalition’s 2014 Spring Training Conference!
Our 2014 Spring Training Conference will take place on April 10! The event will be held at the Fairview Park Marriot in Falls Church, VA, featuring a robust lineup of speakers. Among those that The Coalition has invited for attendance are:
- The Honorable Gerry Connolly, House Committee on Oversight and Government Reform (Invited)
- Cameron Leuty, Senior Budget Analyst, Bloomberg Federal, (Confirmed)
- Richard Levi Counsel to the Inspector General (GSA), (Confirmed)
- Maureen Regan Counsel to the Inspector General (VA), (Confirmed)
- Harry Hallock, Deputy Assistant Secretary, United States Army, (Tentative)
- Jan Frye, Deputy Assistant Secretary, Office of Acquisition and Logistics, (Invited)
- Jeffrey Koses, Senior Procurement Executive, General Services Administration, (Confirmed)
Be sure to follow The Coalition’s events page online, as registration information and a draft agenda will be posted soon!
GOVCon Symposium, February 25
The Coalition for Government Procurement is proud to once again sponsor The Fairfax County Chamber of Commerce GOVCon Symposium – Success Strategies for Surviving in the “New Normal”
Join the Fairfax Chamber and its GovCon Council for the annual GovCon Symposium, which will focus on best practices and success strategies for surviving in the “new normal.” This program will arm you with the tools and insights you need for the year ahead.
Keynote Speaker: U.S. Senator Tim Kaine
Senator Kaine is the junior United States Senator from the Commonwealth of Virginia. As a member of the Committee on the Budget, Senator Kaine will speak about the newly developed federal budget and the implications for the government contracting industry.
Breakout sessions will follow.
Tuesday, February 25, 2014
7:30 AM – 11:30 AM
Hilton McLean Tysons Corner
7920 Jones Branch Drive
McLean, Virginia 22102
For more information and to register visit www.fairfaxchamber.org