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Friday Flash, 02.28.14

FAR and Beyond Blog

As March enters in like a polar bear, it is time to provide an update on the Coalition’s event schedule for March and April.

Myth-Busters Forum with Daniel Gerstein, Acting Under Secretary for Science & Technology (S&T) at the Department of Homeland Security, March 13

On the morning of March 13th the Coalition will be hosting a Myth-Busters Forum with Daniel Gerstein, Acting Under Secretary for Science & Technology (S&T) at the Department of Homeland Security.  The forum will held at the law offices of McKenna Long & Aldridge, LLP.  DHS S&T plays a central and strategic role in supporting/facilitating requirements development, acquisitions and the implementation of cutting edge technologies supporting DHS component offices nationwide.

Cyber solutions, chemical/biological detection technologies, behavioral sciences, and first responder infrastructure, are among the mission capabilities DHS S&T supports across the homeland security enterprise.  DHS S&T is a key interface connecting requirements to technologies through its work with stakeholders within DHS, at the state and local level, internationally, and the private sector.  Our DHS S&T Myth-Busters Forum with Daniel Gerstein focuses on how technology is supporting the DHS mission, and importantly, how industry can engage DHS.  The forum also provides an opportunity for dialogue on the vital role technology identification, development and implementation plays in protecting the homeland.  The forum is a must attend event for industry program managers, account managers and executives focusing on the DHS market.

Myth-Busters webinar on Contractor Assistance Visits under GSA Multiple Award Schedules, March 26

On March 26th, the Coalition will be hosting a Myth-Busters webinar focusing on the processes and procedures for Contractor Assistance Visits under the GSA Multiple Award Schedule program.   As you know, Contractor Assistance Visits are conducted by the Industrial Operations Analysts (IOA) from GSA’s Federal Acquisition Service (FAS).  An MAS contractor can expect 2-3 visits from an IOA over the course of a five year contract period.  It is vital to understand the IOA role and expectations for MAS contractors.

The Myth-Busters webinar features Tom Brady, Director, Supplier Management Division, Office of Acquisition Management at GSA’s Federal Acquisition Service.  Tom will be discussing the respective roles of the Administrative Contracting Officer (ACO) and the IOA.  Topics will include the updated review parameters and processes for IOA visits as well as key compliance issues (e.g. Industrial Funding Fee) surrounding MAS contracts.  This webinar is a “must dial in” event for contractor compliance managers, in house counsel, contracting officers, and executives responsible for management and oversight compliance. Registration information is coming soon!

2014 Spring Training Conference on Opportunities for Success in the Federal Market, April 10

On April 10th, the Coalition will hold our Spring Training Conference at the Fairview Marriott in Falls Church, Virginia.  The theme for this year’s Spring Training Conference is Opportunities for Success in the Federal Market.  The Spring Training Conference’s speakers include representatives from:

  • Department of Army
  • Department of Air Force
  • Department of Health & Human Services
  • Defense Procurement and Acquisition Policy (DPAP)
  • GSA Office of the Chief Acquisition Officer
  • Offices of the GSA Inspector General and VA Inspector General

Our breakout sessions include a session focusing on the GSA FAS Acquisition Centers, the Department of Homeland Security, the IT GWAC programs (GSA, NASA, and NIH), the Small Business Administration, and GSA’s Office of Acquisition Management.  It is a jam packed line up!  To review the agenda and register click here.

The breadth and depth of speakers demonstrates our commitment to fostering a robust Myth-Busters dialogue between government and industry.  Robust dialogue and communication improves understanding and opportunities to deliver best value procurement solutions that support agency missions for the American people.  We look forward to seeing you there!

Roger Waldron



Defense FY15 Budget Preview

The Secretary of the Department of Defense (DoD) Chuck Hagel delivered a budget preview for FY15 on Monday of this week. Hagel noted that defense spending is not expected to reach the levels projected in the five-year budget plan submitted by the President last year.

The Secretary’s FY 15 budget plans include reducing the size of the active-duty Army from its current 522,000 soldiers to between 440,000 and 450,000. Hagel also spoke to management reforms and cutting the DoD’s overhead and operating costs. “Last summer I announced a 20 percent cut in DoD’s major headquarters operating budgets, which is expected to save about $5 billion in operating costs over the next five years.” The DoD is paring back contract spending, making targeted cuts in civilian personnel, improving the quality of financial information and taking other steps to become more efficient – in addition to continuing to implement the more than $200 billion in overhead cuts DoD has submitted in the last three budget proposals. According to the Associated Press, although Congress has agreed on an overall number for the FY15 DoD Budget (just under $500 billion), there are still major decisions to be made about how the money should be spent.


The Danger in GSA’s Supplier Relationship

A new blog post on Federal Times from Roger Waldron discusses the current state of GSA’s supplier relationship. To read the post, click here!


GSA Announces OASIS Small Business Awards

This week, the General Services Administration announced awards to 125 small businesses for its One Acquisition Solution for Integrated Services (OASIS) Small Business (SB) contract.   OASIS SB was developed in response to the government’s substantial need for a hybrid, government-wide acquisition vehicle. The contract for complex professional services will provide a streamlined solution for both commercial and non-commercial needs.  The list of the 125 companies is available on FedBizOpps.


DUNS Required for Schedules

GSA announced this week that contractors that wish to get on a GSA Schedule must have a DUNS number.  DUNS is a unique nine character identification number provided by Dun and Bradstreet.  Further, GSA contractors are to use the same DUNS number at the task order level that was issued at the contract level.  GSA notes that this is important because the DUNS number is used to check various official acquisition-related systems and is a requirement for registering in the System for Award Management (SAM) at


EPA Briefs the Coalition on Ecolabels

The EPA’s Environmental Preferable Purchasing (EPP) program briefed the Green Committee this week on their draft guidelines on ecolabels.  The guidelines are designed to help agencies identify which ecolabels they should use in Federal procurement.  The EPA also hopes to provide more clarity to industry about ecolabels and green standards in the Federal market.

EPA has published the draft guidelines in the Federal Register in order to get feedback from the public on their approach.

The Coalition sincerely thanks Alison Kinn Bennett from the EPA’s EPP program for the briefing and GSA’s Dana Arnold and Brennan Conaway for their participation in the discussion about the ecolabels notice.  The Coalition will submit comments.  Members interested in contributing to the comments, please contact Aubrey Woolley at


FITARA Passes House

The House of Representatives passed the Federal Information Technology Acquisition Reform Act (FITARA) this week.  The bill is sponsored by Oversight and Government Reform Committee Chairman Darrell Issa (R-CA) and Subcommittee on Government Operations Ranking Member Gerry Connolly (D-VA).  The Coalition supports efforts to reform the acquisition of IT to reduce contract duplication and streamline the acquisition process to bring more commercial firms into the Federal market.  For more on FITARA, visit


Compliance Lessons from the Office of Inspector General

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.[1]  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.[2]

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).[3]  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.[4]  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[5] – 32 for initial award, ten for renewals, and four for modifications to add products.[6]  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.[7]

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[8] 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.

[1] 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.

[2] 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.

[3] 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.

[4] 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.

[5] To provide some perspective, the VA estimates that there are currently 1900 contract holders under its FSS program.

[6] 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.

[7] The OIG’s reports labeled eleven post-award reviews as involving voluntary disclosures with a total recovery to the VA of $12,728,288.

[8] This amount includes a $500 million fine resulting from a False Claims Act case against a large pharmaceutical company.


Legal Corner

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,[1] 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.

[1] Contractor Business Ethics Compliance Program and Disclosure Requirements, 73 Fed. Reg. at 67,064, 67,066 (Nov. 12, 2008).


GAO: Strategic Sourcing and Small Business

The Government Accountability Office (GAO) has released a report entitled, Strategic Sourcing: Selected Agencies Should Develop Performance Measures on Inclusion of Small Businesses and OMB Should Improve Monitoring. GAO was asked to review how strategic sourcing affects small businesses, including small disadvantaged businesses. The report examines how the Office of Management and Budget (OMB), GSA, and selected agencies have considered small businesses in their strategic sourcing efforts and the extent to which data and performance measures are available on the inclusion of small businesses in strategic sourcing initiatives. In addition to OMB and GSA, GAO studied agency-wide strategic sourcing initiatives at the Departments of Defense (DoD), specifically Army and the Defense Logistics Agency; Homeland Security (DHS); Housing and Urban Development (HUD); Interior and the National Aeronautics and Space Administration (NASA).

GAO concluded that while OMB, GSA and other selected agencies consider the inclusion of small business when executing strategic sourcing procurements, data and performance measures that would provide a more precise understanding of the inclusion of small and disadvantaged businesses in strategic sourcing initiatives are limited. At GSA, baseline data was collected without performance measures that would determine changes in small business participation in the future. Additionally, other agencies have not collected baseline data and performance measures to determine how small businesses were affected by strategic sourcing.

GAO recommends that GSA, OMB and selected agencies improve data collection and performance measures to better monitor small business participation in the government’s strategic sourcing initiatives. The report did not comment on how small businesses that did not participate in agency strategic sourcing contracts have been impacted.


Draft DHS Acquisition Bill Released

This week, chairman of the Homeland Security Subcommittee on Oversight and Management Efficiency Jeff Duncan (R-S.C.) released a draft bill adding more oversight to the Homeland Security Department’s acquisition process. The bill would require the creation of an acquisition review board, quarterly reviews that would establish multi-year acquisition strategies and Congressional notification for schedule changes. Specifically, the acquisition review board will be made up of the CFO, CIO, CPO, an executive director and led by the undersecretary for management or the DHS deputy secretary. Bolstering the undersecretary for management’s role, the bill provides the ability to “approve, halt, modify …or cancel major acquisition programs.” Additionally, the undersecretary would be responsible for “establishing policies for acquisition that implement an approach that takes into account risks of failure to achieve cost, schedule or performance parameters.”

According to Federal News Radio, each DHS component would have an acquisition component executive, who would answer to the undersecretary for management. The draft bill also alters the role of the Chief Procurement Officer to focus mainly on policy and strategy as well as overseeing DHS’ relationship with vendors and the training and certification of DHS acquisition officials.


Proposed Changes to Annual VETS Reporting

The Department of Labor (DOL) published a Notice of Proposed Rulemaking (NPRM) regarding the Veterans’ Employment and Training Service (VETS) program on February 24. DOL is proposing a number of changes to the VETS reporting that is required of Federal contractors on an annual basis.  In short, the notice proposes:

  • Rescinding the regulations which apply reporting requirements to Government contracts and subcontracts entered into before December 1, 2003
  • Revising the annual report to require contractors and subcontractors to report the specified information for protected veterans in the aggregate rather than for each of the categories of veterans
  • Revising the regulations that address the definitions of terms, the text of the reporting requirements clause included in Government contracts and subcontracts, and the methods of filing the annual report

The notice proposes that the above changes in VETS reporting go into effect one year after the effective date of the final rule.  Comments are due to the Labor Department by April 25, 2014.  To access the VETS NPRM, visit


Chairman Graves Small Business Legislation

Federal News Radio reports that Congressman Sam Graves (R-Mo.), chairman of the Small Business Committee, introduced two bills this week designed to increase opportunities for small businesses selling goods and services to the government.

  • The Greater Opportunities for Small Business Act of 2014 proposes to raise the percentage of contracts that are mandated to go to small firms to 25 percent. Additionally, the bill would create a goal for agencies to ensure 40 percent of all subcontract awards go to small businesses and require that only prime contract awards can count toward the prime contract goal.
  • The Contracting Data and Bundling Accountability Act of 2014 would affect contract bundling by “requiring the Small Business Administration to work with other agencies to create and implement a data quality improvement plan to promote greater accuracy, transparency and accountability in the reporting of contract bundling and consolidation.” It then requires the Government Accountability Office to initiate a study on the effectiveness of the plan that assesses whether contracts were accurately labeled as bundled or consolidated.


Off the Shelf: Will there be acquisition reform in 2014?


This week on Off the Shelf, Jon Etherton, president of Etherton & Associates, discusses the prospects for acquisition reform on the Hill. For the first time in many years, Congress has significant interest in the acquisition system and is looking for opportunities to improve its performance. Etherton provides his insights on how this renewed focus on “reform” of acquisition may play out in 2014 and beyond. He also puts the current focus in context, sharing his experiences working on acquisition related reforms sparked by the Section 800 panel report in the 1990’s, the last era of reform. To listen to the show, click here.


DPAP Extends Comment Period for DFARS Notice

DoD has extended the comment period on the Review of Statutory and Regulatory Requirements notice. Comments are now due April 23, 2014.

The office of Defense Procurement and Acquisition Policy (DPAP) is requesting feedback on the burdens/impacts associated with certain DFARS requirements.  Specifically, DPAP would like input on:

  • Particular impacts associated with contracting statutes;
  • Why the identified impact does not achieve the intended benefit of the identified legislation, or why the intended benefit is not helpful to the Department; and
  • Any recommendations for alternative approaches to achieve the intended benefit of the identified legislation.

The GWAC/MAC Committee will provide comments.  We plan to focus on the DFARS subpart on Interagency Acquisition, and any other provisions suggested by members.  If you’d like to join the working group that is preparing these comments, please contact Roy Dicharry at


Announcement about Friend and Colleague, Jerry Effer

Recently the Coalition has lost a long-time friend and former staffer, Jerry Effer, to cancer.  As many of us remember, Jerry was the principle force in the early growth of the Coalition, helping to build the strong foundation we stand on today.   Jerry will be greatly missed.  We send our thoughts and prayers to his friends and family on behalf of the entire membership.


Forum with Under Secretary for Science and Technology at DHS, Daniel Gerstein

The Coalition is excited to announce our next breakfast forum event with Under Secretary for Science and Technology at DHS, Daniel Gerstein.  This event will be held on Thursday, March 13 from 8:30 – 10:30 at McKenna Long & Aldridge LLP in Washington, D.C.


  • Brief federal contractors/industry representatives on DHS S&T
  • Explain S&T priority areas, recent successes with industry partners
  • Provide insights into how industry can best work with S&T, where S&T is going


  • S&T 101
  • Game Changers & hot challenges
  • Innovation
  • Looking to the future – how industry can help
  • How to work in current financial environment
  • Importance of industry partnerships


McKenna Long & Aldridge LLP – 1900 K Street NW, Washington, DC 20006


Small Business Committee Meeting

Coalition members are invited to join us at the upcoming Coalition Small Business Committee meeting.  This will be a first of its kind meeting in that Chairmen from each of the Coalition’s committees will be present to discuss their objectives and priorities.  In addition:

  • Robert Bourne and Matt McFarland from GSA’s Office of Acquisition Management will discuss their efforts on GSA Schedule contractor teaming, and
  • A panel of small and large Coalition members will share best practices for GSA Schedule contractor teaming arrangements.

The meeting will be held on March 6 from 10:00 to 12:00 at the law office of Holland and Knight 1600 Tysons Blvd, Suite 700,Tysons Corner, VA 22102. Please RSVP to Roy Dicharry if you wish to attend.


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.

View the Draft Agenda Here!

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!

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