Friday Flash, 05.16.14

FAR and Beyond Blog

Before we wrap up the month of May, I want to make sure you are aware of two exciting events and two committee meetings that will be taking place in the coming weeks.

The New Guidance on Cybersecurity Acquisition will be held on May 22nd from 8:00am – 11:00am at the Tower Club in Tysons Corner.  This event will include a panel comprised of officials from GSA, DOD, NIST, and several law firms who will all discuss the implications for contractors of the new DOD and GSA final report and guidance on cybersecurity acquisition, including an overview and update on the Draft Implementation Plan and NIST cybersecurity requirement for critical infrastructure.  This forum is a unique opportunity for your company to voice industry comments, questions, and concerns on the report to government officials who play an active role in the policy implementation.  Additionally, we will take a short break during the morning panel discussion to allow for networking both with peers and the panel participants.  This will be a very informative event and we highly encourage you to share information about this session with colleagues in your company responsible for cybersecurity.

Our second event will be a Premier Member only event (plus Strategic Partners and Keystones) with Tom Sharpe, May 29th from 8:30 – 10:30am at Northrop Grumman in McLean.  Mr. Sharp is the Commissioner of the Federal Acquisition Service (FAS) and we invite you to come hear him describe in detail the three year strategic plan for FAS, which will include GSA’s role as “America’s Buyer” and how to achieve a growing market share.

Regarding important committee meetings I wanted to highlight, the GWAC/MAC Committee is scheduled to meet on Tuesday, May 20th at 10:00am at Deloitte in McLean.  Tiffany Hixson, Regional Commissioner, Northwest Arctic Region at GSA will be joining the committee for a valuable discussion.  If that wasn’t enough, Kevin Gallo and/or Fred Haines, Telecommunications Managers with GSA’s Integrated Technology Services, will also be joining the meeting at 11:00 to discuss the acquisition strategy for the upcoming NS2020 procurement.

Lastly, Jan Frye, the Deputy Assistant Secretary for Acquisition and Logistics, U.S. Department of Veterans Affairs, is meeting with the Healthcare Committee on May 28^th at 10:00 at McKenna Long & Aldridge in Washington, D.C.  The Coalition is extending this unique opportunity to have a small group conversation with the head of one of the largest acquisition and logistics programs in the federal government to all Coalition members.   Jan manages and oversees the development and implementation of policies and procedures for department-wide acquisition and logistics programs supporting all VA facilities. His responsibilities include management of VA’s National Acquisition Center in Hines, Illinois, the Technical Acquisition Center in Eatontown, NJ, the Centers for Acquisition Innovation in Austin, Texas and Washington, D.C., the VA Acquisition Academy in Frederick, Maryland, and the Denver Acquisition and Logistics Center in Denver, Colorado. He also serves as the VA Senior Procurement Executive.  Join the discussion to better understand major VA acquisitions across a broad spectrum of items including Healthcare,  IT and services; VA acquisition priorities; and overall budget outlook.

Please see a summary below of dates and details and feel free to pass this along to any of your internal colleagues you think would benefit from attending.  For assistance with event registration, please contact Matt Cahill at 202-315-1054 or mcahill@thecgp.org.  For assistance with committee meeting registration, please contact Roy Dicharry at 202-331-0975 or rdicharry@thecgp.org.  Note that it’s imperative you RSVP with Roy for the committee meetings due to building security procedures.

1. Tues., May 20 – GWAC/MAC Committee Speakers: Tiffany Hixson, Regional Commissioner, Northwest Arctic Region Kevin Gallo and/or Fred Haines, Telecommunications Managers with GSA’s Integrated Technology Services
Deloitte
1750 Tysons Blvd, McLean, VA
10:00am – 12:00pm
(Slots are going fast. Members who would like to attend, please RSVP to Roy Dicharry at rdicharry@thecgp.org ASAP.)

2. Thurs., May 22 – The New Guidance on Cybersecurity Acquisition (featuring DoD, NIST, GSA speakers and legal experts)
Tower Club
8000 Towers Crescent Drive, Suite 1700, Vienna, VA
8:00am – 11:00am

3. Wed., May 28 – Healthcare Committee
VA Acquisition: Meet with Jan Frye, Deputy Assistant Secretary, Office of Acquisition and Logistics at the Department of Veterans Affairs
McKenna Long & Aldridge
1900 K Street NW, Washington, DC
10:00am – 12:00pm

4. Thurs., May 29 – Premier Member only event (plus Strategic Partners and Keystones) with Tom Sharpe, Commissioner of the Federal Acquisition Service (FAS)
Northrop Grumman
7575 Coleshire Drive, McLean, VA
8:30am – 10:30am

Matt Cahill

Vice President, Membership and Marketing

 

NITAAC CIO-CS Released

The National Institutes of Health’s Information Technology Acquisition and Assessment Center (NITAAC) has released the solicitation for the $20 billion Chief Information Officer–Commodity Solutions (CIO-CS) Government-wide Acquisition Contract (GWAC). The vehicle will be a 10-year indefinite-delivery/indefinite-quantity (IDIQ) contract that will be available to all federal agencies to purchase IT commodities and solutions using fixed-price delivery orders. According to the solicitation, the contract will provide on-premise as well as cloud-based IT products and services all in support of security, infrastructure, telecommunications, desktop applications and health and life sciences. CIO-CS will replace the existing Electronic Commodities Store (ECS III) contract program that expires in November. Members should note that bids are due by June 11, 2014.

 

VanRoekel Testimony: Tech FAR Guidance and IT Oversight Fund

In testimony before the Senate Appropriations Subcommittee on Financial Services And General Government and the Homeland Security and Governmental Affairs Committee last week, Federal Chief Information Officer Steven VanRoekel described new initiatives in Federal IT including,  the “Tech Federal Acquisition Regulation (FAR) Guide” and a new IT Oversight and Reform Fund.

According to his testimony, the Administration plans to create a compilation of the 21st Century, agile aspects of the FAR that will guide agencies in soliciting services in new ways—“ways that more closely match techniques used by the private sector.” VanRoekel said that the new techniques might include using challenges and crowdsourcing approaches to involve citizens, writing requirements that allow for more flexible execution, or a pay-for-service model. Additionally, the guide will include FAR-allowed processes used by agencies that have successfully implemented IT projects in the past.

Also highlighted in last week’s testimony, the FY2015 budget specifically requests $20 million for the Information Technology Oversight and Reform (ITOR) fund. The fund will use data, analytics and digital services to improve the efficiency, effectiveness and security of Government operations and programs.

 

Bart Bush on GSA Consolidation Projects, June 5

Join the Federal Buildings Committee on June 5th at 10am for a conversation with Bart Bush, Assistant Commissioner of the Office of Client Solutions in the Public Buildings Service (PBS).  Mr. Bush will be discussing GSA’s efforts to reduce the Federal footprint through consolidation projects.  GSA recently announced a $70 million investment in 19 consolidation projects with Federal agencies across the country.  These projects are designed to reduce costs by eliminating multiple leases and to also improve environmental performance.

Federal Buildings Committee

June 5 at 10am

Mayer Brown

1999 K St NW

Washington, DC

All members are welcome to join the discussion.  To attend, please RSVP to Roy Dicharry at rdicharry@thecgp.org.

 

GSA Seeking Applications for QPC Board

GSA is currently seeking applications for Quality Partnership Council (QPC) Board Member positions/representatives for all six schedules managed by the Integrated Workplace Acquisition Center.

The goal of the QPC board is to work together to discuss relevant issues affecting procurement within the federal government.  Board members are required to attend conference calls on a quarterly, or more if needed, basis and in-person meetings estimated at two meetings per year.  Members represent their industry (not company) and engage in discussion with other members to solicit their feedback for board meetings.  The approximate involvement would include 20+ hours per year, which includes board member calls, attending QPC meetings and additional time if needed.

Board members hold their position for two years from the time they are selected.

Note, if you are not affiliated with these industries, or are a federal customer, you are still encouraged to apply and will be considered.  In order to be considered, please fill out the application form by Friday, May 30, 2014.  If you have any questions, please contact IWAC.BD@gsa.gov.

 

DATA Act Signed into Law

President Obama has signed into law the Digital Accountability and Transparency Act of 2014 (S. 994). The bill requires the Treasury Department and the Office of Management and Budget (OMB) to establish government-wide standards for financial data.  This information will be published publicly at USASpending.gov. Reported financial data will include Federal agency expenditures on contracts, loans, and grants.  Agency inspector generals are to report on the quality and completeness of the spending data submitted by their respective agencies every two years.

The DATA Act also establishes a two-year pilot program covering Federal contracts, grants, and subawards valued at over $1 billion.  The objectives of the pilot include eliminating unnecessary duplication in financial reporting and a reduction in compliance costs for recipients of Federal awards.  Following the pilot, OMB will review the data and report on the usefulness of the information collected and the associated costs.  To review the full DATA Act, visit http://beta.congress.gov/bill/113th-congress/senate-bill/994.

 

CGP Briefing on Cybersecurity Acquisition – May 22nd

The Tower Club, Tysons Corner, VA

May 22, 2014, 8:00AM – 11:00AM, Registration 7:30AM

Registration Fee: Premier Member $95; Standard Member $145; Non-Member $215

The Coalition will host a morning panel discussion and workshop on the implications for contractors of the new DoD and GSA final report on cybersecurity acquisition – including an overview and update on the Draft Implementation Plan and NIST cybersecurity requirement for critical infrastructure.

Confirmed Speakers:

• Jon Boyens, Senior Advisor for Information Security, NIST
• Emile Monette, Senior Advisor for Cybersecurity, GSA Office of Mission Assurance
• Don Johnson, USD (AT&L) | DASD (C3Cyber)
• Richard Blake, Business Management Specialist with GSA’s Federal Acquisition Service Enterprise GWAC Center, San Diego (pending travel approval)
• Ken Evans Jr., Deputy Product Manager for the Army Information Warfare Product Office
• Tom Barletta, Partner, Steptoe & Johnson
• David Z. Bodenheimer, Partner, Crowell &
  Moring LLP
• Beth Ferrell, Partner, McKenna Long & Aldridge
• More to come!

A primary purpose of the DoD – GSA Final Report is to recommend strategic guidelines for acquisition practitioners. In addition to covering the substantive materials, panelists will discuss the following issues as they relate to the new guidance, NIST Framework, and DFARS rule:

• How government, schedule, and commercial contractors should prepare and respond to the new guidance in proposal efforts
• Is it likely that the new guidance will move from voluntary to mandatory for contractors in the near future?
• With an estimated $46 Billion spent on global critical infrastructure cybersecurity in 2013, how much is enough?
• Are Risk Management principles and Best Practices management sufficient in this current threat and vulnerability environment?
• Are there implications in the new guidance for the certification and qualifications of FedRAMP contractors in providing cloud services?

We are confident that the information, sources, and resources covered will strengthen your cybersecurity efforts and expand your knowledge in this critical area and we look forward to your participation.

To register, click HERE!

 

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.

Legal Corner

Proposed Rule Reflects Questionable Implementation of Statute to Expand Application of Personal Conflict of Interest Rules

By: Jason A. “Jay” Carey, Partner, McKenna Long & Aldridge LLP; Alison L. Doyle, Partner, McKenna Long & Aldridge LLP; John W. Sorrenti, Associate, McKenna Long & Aldridge LLP

The Federal Acquisition Regulation (“FAR”) currently imposes personal conflict of interest (“PCI”) requirements on contractors performing acquisition functions closely associated with inherently governmental functions.  FAR subpart 3.11.  Contractors performing such work must screen for and prevent PCIs, and the screening process includes disclosure and review of covered employees’ financial interests and other relationships.  Compliance can be a significant burden and understandably raises concerns about the proliferation of personal financial information in the hands of contractors and the government.

On April 2, 2014, the FAR Council issued a proposed rule that would greatly expand the application of those PCI requirements to contractors performing a number of other (non-acquisition) “functions closely associated with inherently governmental functions,” as well as contracts for personal services.  79 Fed. Reg. 18503 (Apr. 2, 2014).  The proposed rule’s implementation of the underlying statute raises red flags, and would require many new contractors to accept significant and ambiguous compliance burdens.  Comments are due by June 2, 2014.

The proposed rule purports to implement section 829 of the National Defense Authorization Act for Fiscal Year 2013, which required the Secretary of Defense to review existing PCI requirements to determine whether they should be extended to other defense contractors through a revision of the Department of Defense supplement to the FAR.  The proposed rule, however, goes beyond the stated intent of section 829, extending the requirement to all agencies, not just the Department of Defense.  Contractors and industry groups submitting comments may want to address the propriety of this approach given the statutory language.

With respect to the substantive requirements of the proposed rule, it deletes the current limitation to acquisition-related functions, and applies PCI rules to all contractor “functions closely associated with inherently governmental functions.”  Section 829 referred to 10 U.S.C. § 2838(b)(3) to define the term “functions closely associated with inherently governmental functions,” and that statutory provision defined the term as the list of functions in FAR § 7.503(d).  The proposed rule, however, does not adopt this definition — and, in fact, does not define the term at all.  Rather, the rule refers generally to FAR subpart 7.5.  But that subpart does not define the term, or even contain the words “closely associated.”  As a result, the proposed rule provides no guidance to contracting officers regarding what it means for a function to be “closely associated” with inherently governmental functions.  Leaving this essential term undefined will assuredly create confusion, and lead to an inconsistent and uneven application of the rule from agency to agency and contracting officer to contracting officer.  And over time, agencies will gravitate to the most conservative approach — i.e., the broadest application — without any systematic assessment of whether that approach makes sense, or is worth the cost to contractors and the procurement system.

Further complicating matters is the ambiguity of the functions listed in FAR § 7.503(d), which sweep in a wide range of services that support government operations, including:

• Budget preparation (including workload modeling, fact-finding, efficiency studies, and should-cost analyses);
• Reorganization and planning activities;
• Development of policies or regulations (including analyses, feasibility studies, and strategy options);
• Any situation that might permit a contractor to gain access to confidential business information or other sensitive information;
• Support for responses to Freedom of Information Act requests;
• Some legal, security, and inspection-related services.

The FAR Council is interested in receiving comments on which functions listed in FAR § 7.503(d) should be included or excluded from the PCI requirements.  In addition to addressing that question, contractors and industry groups should consider commenting on the ambiguous scope of the covered functions in FAR § 7.503, which is certain to lead to uneven implementation.  For example, the new PCI rule would apply to contracts where the contractor may have access to “confidential business information” or “other sensitive information.”  See FAR § 7.503(d)(11).  Those terms are not defined, and have potentially broad application — not just to contractor proprietary information and source selection information, but also to any information the government views as confidential or sensitive.  The reference to “planning activities” in FAR § 7.503(d)(2) is similarly broad and undefined.

Given the absence of any definition of “closely associated,” the lack of clarity in FAR § 7.503, and the conservative nature of many in the acquisition workforce, a broad application of PCI requirements seems likely if the proposed rule is adopted as-is.  As currently drafted, the proposed rule has far-reaching implications, and is likely to impose substantial costs and compliance burdens on contractors — beyond what even Congress intended.  Contractors should consider submitting comments, and closely monitor the progress of the proposed rule.

 

New $2 Billion in ESPCs Announced

According to an announcement last week, President Obama is requiring agencies to enter into an additional $2 billion in energy savings performance contracts (ESPCs) to support energy efficient investments at federal facilities. Under an ESPC, a vendor pays the upfront costs of the investment in exchange for payments from energy cost savings over time. The contractor guarantees that the improvements will generate energy cost savings to pay for the project over the term of the contract. The additional $2 billion in combination with the initial commitment of $2 billion in 2011, will result in a total of $4 billion in energy efficiency performance contracts in the Federal sector through 2016. The aim of the program will be to save Americans billions in energy costs, promote energy independence, and, according to independent estimates, create tens of thousands of jobs in the hard-hit construction sector.

 

Off the Shelf with Brian Miller

This week on Off the Shelf, Brian Miller, managing director, Disputes and Investigations for Navigant, and former inspector general for the General Services Administration, provides his insights regarding MAS audits, the mandatory disclosure rule as well as the best practices for contract compliance.

Miller also discusses the role the IG plays within GSA, including efforts to retrieve lost and stolen federal artwork commissioned during the 1930’s as part of the Works Progress Administration (WPA).

He also shares his experiences in the Department of Justice working on healthcare fraud, and cases coming out of 9/11. To listen to the program, click here.

 

The Latest on 18F

Last Friday, GSA held an 18F demo day for government agencies and vendors. Representatives from across federal government and contractors got a firsthand look at upcoming projects developed by 18F, the recently launched digital incubator at the U.S. General Services Administration (GSA).

Projects that were featured at the demo day included:

• FBOpen, a set of open-source tools to help businesses search for opportunities to work with the U.S. Government.
• SBIR Search, Small Business Innovation Research (SBIR) search makes the filtering, inclusion, addition, and updating of SBIR opportunities more efficient. The search links opportunities to the original system of record (FedBizOpps or Grants.gov) for automated updates
• Midas Innovation Platform, an open source software platform, developed in partnership with the Department of State, that facilitates innovation and collaborative work.

The Coalition recently submitted a letter to GSA concerning the new 18F initiative. The letter can be viewed here: https://thecgp.org/images/18F-Letter-Final.pdf.

Upcoming Coalition Meeting with 18F

The week of June 23rd, the 18F team will meet with Coalition members to introduce their program, vision and role innovating technology projects for customer agencies at GSA. We will provide you with more details in the Friday Flash as they come available.

 

OFPP: FAC-C Refreshed to Strengthen the Workforce

On May 7,  the Office of Federal Procurement Policy (OFPP)  released a memorandum concerning revisions to the Federal Acquisition Certification in Contracting (FAC-C), effective October 1, 2014. The memo refreshes OFPP’s FAC-C to better align it with the Department of Defense’s (DoD’s) Defense Acquisition Workforce Improvement Act (DAWIA) contracting certification curriculum and strengthen the development of contracting professionals through targeted training.  This refresh reflects the recommendation of the multi-agency Contracting Functional Advisory Board (CONFAB) to strengthen the acquisition workforce to improve program outcomes.

The refreshed FAC-C will include the following:

• Additional training, experience, and continuous learning requirements for FAC-C holders who manage acquisitions requiring specialized knowledge, skills, and abilities. Specialization is being considered for areas such as IT, services, construction, and small business acquisition.
• Curriculum that aligns more closely with the Defense Acquisition Improvement Act (DAWIA) curriculum.  For example:
  • Level I classes now include FAR basics and cost/price analysis.
  • Level II classes include more focus on intermediate cost/price analysis and supply and service contracting.
  • Level III classes include electives such as Understanding Industry, Acquisition Law, and Advanced Contract Pricing to target advanced coursework in acquisition–related topics.

Contracting Officers and other contracting professionals in the 1102 job series must be certified at an appropriate level as of October 1, 2014.  For more information on the FAC-C refresh, click here.

 

Meet Jan Frye on VA Acquisition, May 28

Coalition members are invited to attend a meeting with Jan Frye, Deputy Assistant Secretary Office of Acquisition and Logistics at the Department of Veterans Affairs on May 28 (rescheduled date).

This is a unique opportunity for members to hear from Jan Frye on the latest acquisition initiatives at the VA designed to support America’s Veterans.  The May 28 meeting will be at 10:00am at McKenna Long & Aldridge (1900 K Street, Washington, DC 20006). To attend in person, RSVP to Roy Dicharry at rdicharry@thecgp.org.