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Friday Flash 05/17/2024

The Benefits of “Best Value” for Small Businesses in the Federal Market

As discussed previously in this FAR and Beyond blog, the General Services Administration (GSA) has proposed to amend the Competition in Contracting Act (CICA) of 1984 to adjust the statutory authority for the Federal Supply Schedule (Schedule) program by clarifying what constitutes “competitive procedures” under the law. Currently, the Schedule program is deemed a competitive procedure if participation is open to all responsible sources and orders and contracts under the program result in the lowest overall cost alternative to meet the government’s needs. Under GSA’s proposed legislation, the Schedule program authority would retain the requirement that it be open to all responsible sources, but would change the requirement that awards result in the “lowest cost alternative” to a requirement that awards result in “best value” for the Federal Government. The proposed change will benefit both businesses and customer agencies, and will be particularly beneficial to small businesses and new entrants, including small disadvantaged, service-disabled veteran-owned, women-owned, and HUBZone small business concerns.

The number of small businesses participating in the Federal market has plummeted in the last decade, and this downward trend continued in 2023. There are many factors: e.g., unintended consequences of category management, increased regulatory compliance, and instability in the market due to continuing resolutions and recurring threats of government shutdowns. In addition, the one governmentwide contracting program created to attract commercial firms to the Federal market, which also represents the single, largest contracting program for small businesses, the Schedule, is not reflecting commercial practices due to recent policy changes. Unfortunately, Schedule contractors now face a long, painful slog negotiating contract pricing at the contract level, instead of relying on competition at the task or delivery order level to provide fair and reasonable pricing. The Schedule solicitation asks offerors to provide pricing that is lower than the price offered to their best commercial customer, in exchange for a paltry minimum guarantee of only $2,500, with the expressed intent to push for additional discounts at the order level. The price reduction clause, which requires contractors to monitor commercial pricing to ensure that the government is not being charged more than an agreed upon reference pricing for a good or service, is not a commercial practice and exposes prospective contractors to burdensome record-keeping requirements and potential criminal and civil liability.

There is also a lack of consistency in how laws, regulations, and policies are applied to Schedule offerors and contractors by individual contracting officers. For example, in contract negotiation some contracting officers request invoices for every item, requiring offerors to provide invoices for millions of products. Providing invoices for thousands or millions of items to establish pricing defies logic when it is highly unlikely the contracting officer will have the time or expertise to review them. Further, the invoice requirement is a roadblock for small businesses offering new technologies and products, as those businesses may not have the resources necessary to monitor pricing effectively. Some contracting officers attempt to renegotiate already approved prices when modifications are requested for an unrelated item or service. It is well settled that the requirement for award to small businesses at fair market prices does not equate to lowest possible price. This understanding must be embraced if we want to attract new entrants and the best technology and innovation to the Federal market through the Schedule program. 

Given this backdrop, it is not surprising that Other Transaction Authority spending has exploded; it allows the Government to quickly buy the best innovative goods and services from small firms that are unwilling to deal with FAR clauses, oppressive contract negotiation and reporting requirements, or bid protests and associated delays. If we want small businesses and new entrants to enter the Federal market and stay in it, the Schedule needs to return to its roots as a convenient, easy tool for customer agencies to acquire the best commercial goods and services.

GSA’s best value legislative proposal will allow GSA to craft policies and procedures that more closely align with the commercial market, eliminating costly, overly burdensome contract negotiation, reporting, and administration processes that serve as barriers to entry for small businesses. The result will be more opportunity for small businesses offering innovative, best value solutions to meet customer agency requirements. If the best and most innovative firms are enticed to participate in the Federal market through the Schedule, competition at the order level, which includes price, will result in best value for customer agencies, and ultimately, the taxpayer.

Happy 50th Anniversary to the Office of Federal Procurement Policy 

On Tuesday, the Office of Management and Budget (OMB) Office of Federal Procurement Policy (OFPP) held a 50th anniversary celebration at the Eisenhower Executive Office Building on the White House campus. The event, which featured remarks from senior OMB and OFPP officials, was attended by current and former procurement leaders who gathered to celebrate OFPP’s work to promote economy, efficiency, and effectiveness in the Federal acquisition system since 1974. The Coalition was honored to join in the celebration and congratulates OFPP on its 50th anniversary. On behalf of our members, we look forward to continuing the partnership to promote common sense in Federal procurement! 

Check out the Photos from the Spring Training Conference 

Thank you to all who attended the Coalition’s Spring Training Conference – What is Fair and Reasonable, Part 2: Let’s Continue the Dialogue! on May 8-9. We hope that you enjoyed the opportunity to hear the latest updates on key Federal contracts and related initiatives from government officials and acquisition experts, as well as network with friends and colleagues.  

Photos from the conference are now available! View the photos from day one, and day two. Our sincere thanks to Susan Hornyak Photography for capturing all of the best moments at the conference!  


As a reminder, slides from the conference sessions were sent to all registrants on Wednesday afternoon. If you registered for the conference and need access to these materials, please contact Michael Hanafin at

Take the Spring Training Conference Survey

We appreciate everyone who joined us at the conference and value your feedback! Please take a brief survey of the Spring Training Conference by clicking HERE. Your thoughts will help us to make sure that our future events feature the topics, Government speakers and Federal contract programs that are of most interest to members. The survey will be open through next Friday, May 23.  

NIST Updates Guidance for Contractors Handling CUI 

On Tuesday, May 14, the National Institute of Standards and Technology (NIST) released the third revision to its guidance for protecting Federal controlled unclassified information (CUI) on non-Federal systems, NIST Special Publication (SP) 800-171. In a news release, NIST said that “contractors and other organizations that do business with the Federal Government now have clearer, more straightforward guidance for protecting the sensitive data they handle.” The release also includes a revision of the corresponding assessment guidance, NIST SP 800-171A, for evaluating compliance with the requirements.  

The most extensive change in the revision is the realignment of security requirements in 800-171. They now harmonize with NIST’s source catalog of security and privacy controls for Federal information systems, NIST SP 800-53. In addition, security requirements are defined in more detail than in the previous revision.  

In addition to revising existing requirements, NIST also added three new families of security requirements: Planning, System and Services Acquisition, and Supply Chain Risk Management. Other important changes include the introduction of organization-defined parameters (ODPs) to help organizations adapt requirements to their needs and new tailoring criteria to guide the selection of requirements.  

NIST provided a full list of changes on the in documentation for the release. 

The timing of when contractors who handle CUI must comply with the new guidance will depend on their contracts and agency customers. The Department of Defense has already released a class deviation delaying the implementation of the revision indefinitely, and the draft rule for the Department’s Cybersecurity Maturity Model Certification (CMMC) Program explicitly requires compliance with revision 2 rather than the latest revision of 800-171. 

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New Leadership to Shape FedRAMP’s Future 

The past two weeks brough two important developments for the Federal Risk and Authorization Management Program (FedRAMP) which is responsible for managing the authorizations to operate for cloud services in the Federal Government. First, GSA announced that Lawrence Hale, the Deputy Assistant Commissioner for the Office of Information Technology in the Federal Acquisition Service, will be the Chairman of the Federal Secure Cloud Advisory Committee (FSCAC). FSCAC, formed last year, advises GSA on the development of FedRAMP and includes both government and industry participants. Its next public meeting will take place on May 20 from 11:00 AM to 3:00 PM (ET). (Additional details and registration information is available here.) 

In addition, on May 14, GSA announced that the Office of Management and Budget appointed a new FedRAMP Authorization Board to replace the legacy Joint Authorization Board, as required by the FedRAMP Act passed last year. “The new board brings a wealth of technology, cybersecurity, and engineering expertise from Federal agency executives who will work to champion the vision of FedRAMP and make that vision successful,” said Eric Mill, GSA’s Executive Director for Cloud Strategy. “The board will approve and help guide FedRAMP policies, bring together the Federal community to create a robust authorization ecosystem, and be a critical partner to the FedRAMP program in our shared goal of a more streamlined customer experience and stronger Federal cybersecurity.” The board’s seven inaugural members are: 

  • Hemant Baidwan, Chief Information Security Officer, Department of Homeland Security; 
  • David McKeown, Senior Information Security Officer and Deputy Chief Information Officer for Cybersecurity, Department of Defense; 
  • Carrie Lee, Deputy Chief Information Officer, Department of Veterans Affairs; 
  • Venice Goodwine, Chief Information Officer, Department of the Air Force; 
  • Christopher Butera, Senior Technical Director for Cybersecurity Division, Cybersecurity and Infrastructure Agency; 
  • Sylvia Burns, Chief Information Officer and Chief Privacy Officer, Federal Deposit Insurance Corporation; and 
  • Bo Berlas, Chief Information Security Officer, U.S. General Services Administration. 

The FedRAMP Authorization Board’s initial tasks will be ensuring a smooth transition from the Joint Authorization Board, continuing to perform authorizations and continuous monitoring, and defining metrics for FedRAMP. 

GSA to Begin Software Attestation on June 8  

On Wednesday, May 15, GSA released a second Supplement to Acquisition Letter MV-2023-02, Ensuring Only Approved Software is Acquired and Used at GSA. The supplement notifies industry that on June 8, 2024, GSA will start collecting Common Forms for new contracts (including micro-purchases) and the exercise of contract options that include the use of software, regardless of whether the software is considered critical. GSA will update its policy regarding the process for collecting, reviewing, retaining, and monitoring attestation information by June 8, 2024. 

The Common Form for GSA’s use can be found on both the GSA Acquisition Portal Cyber-Supply Chain Risk Management (C-SCRM) page and’s Acquisition Policy Library and Resources page. GSA will collect Common Forms directly from offerors and contractors as needed. According to GSA, if a valid form has already been posted in the CISA’s repository, there is no need to obtain a separate attestation. 

         Appian – Gold Sponsor of the Spring Training Conference

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Senators Call for Greater Oversight of the VA’s Electronic Health Records 

Last week, Senators Jon Tester (D-MT), Patty Murray (D-WA), and Sherrod Brown (D-OH) submitted a letter to the Department of Veterans Affairs (VA) calling for the agency to re-review terms and incorporate additional oversight provisions during the ongoing contract negotiations for the Electronic Health Record (EHR) Modernization Program. In May 2023, the VA announced a revised EHR agreement that included several provisions in multiple areas like system reliability and contractor responsiveness. The letter highlights these changes to the contract as steps forward, such as the shift from a five-year term to five one-year terms to provide the VA with the opportunity to review the contract annually and renegotiate as appropriate. While the lawmakers noted advancements in the EHR system since the updated agreement, they also found areas for improvement. The letter requests that following the end of current negotiations, the VA provide a summary of the new enforcement provisions and how it has used the 2023 revised agreement to achieve better outcomes.  

Sponsorships Now Available for the Annual Golf Tournament  

The Coalition’s Annual Charity Golf Tournament is a popular event that will take place on August 21, 2024 at the beautiful Whiskey Creek Golf Club in Ijamsville, MD. This event attracts golfers of all skill levels eager to enjoy some friendly competition with friends and colleagues while supporting a wonderful cause for our veterans. We have raised over $135,000 for The Coalition for Government Procurement Scholarship Fund to assist qualified veterans pursuing a graduate degree in U.S. government procurement at GWU. In addition, tournament proceeds support Paws for Purple Hearts, an organization that strives to improve the lives of veterans and wounded service members facing mobility challenges and trauma-related conditions by providing the highest quality assistance dogs and canine-assisted therapeutic programs.  

Multiple sponsorships are available for this year’s tournament, including: 

  • Title Sponsorships – $6,000/each 
  • Reception Sponsorships – $4,000/each 
  • Lunch Sponsorships – $4,000/each 
  • All-Day Beverage Cart Sponsorships – $2,500/each 
  • Longest Drive/Closest to the Pin Sponsorship – $1,500 
  • Hole Sponsorships with 4 Players – $1,200/each 
  • Veranda Club Sponsorships – $150/each 
  • Hole Sponsorships (no players) – $500/each 
  • Golf Foursomes – $800/each 
  • Single Golfer – $210/each 

View the full list of sponsorship opportunities here. For more information, please contact Heather Tarpley at  

Thank you to our current sponsors: 

Registration for the golf tournament will open next week. Stay tuned for more details!

GSA Seeking Input on Potential PFAS Restrictions  

The Coalition is seeking feedback on a Request for Information (RFI) from GSA regarding per- and polyfluoroalkyl substances (PFAS) in Federal procurement. The purpose of GSA’s RFI is to gather information to support a PFAS removal requirement from the Office of Management and Budget and to inform a potential rulemaking “on how to best reduce Federal procurement of products that either intentionally or unintentionally contain PFAS while minimizing any unnecessary burdens on our industry and logistics partners.” The RFI has 18 questions pertaining to PFAS-related issues, including on ecolabels, mitigations, and limits. Some questions include: 

  • Aside from a product’s ecolabel, are there other ways to identify if a product contains PFAS?  
  • Considering GSA’s goal to reduce products containing PFAS, what product categories have the greatest opportunity for GSA to reduce or eliminate PFAS exposure? 
  • What is the potential impact on domestic manufacturing if GSA establishes PFAS reduction requirements that reduce or prohibit PFAS, or eliminate them entirely? 

To see the full list of questions, click here

If your organization would like to contribute to the Coalition’s response to the RFI, please submit your feedback to Michael Hanafin at by Friday, May 31. All feedback is due to GSA on June 17, 2024. 

The Legal Corner provides the procurement community with an opportunity to share insights and comments on relevant legal issues of the day. The comments herein do not necessarily reflect the views of The Coalition for Government Procurement.


On April 1, 2024, the Government Accountability Office (GAO) sustained a bid protest by TLS Joint Venture, LLC because the awardee’s registration in the System for Award Management (SAM) lapsed before the government awarded the contract.1 Federal contractors should avoid the risk of being found ineligible for award by ensuring that their SAM registration remains current—and does not become a roadblock to receiving a potentially lucrative government contract.


The protest related to a Department of the Navy procurement for custodial services. The request for proposals incorporated Federal Acquisition Regulation (FAR) section 52.204-7, System for Award Management. And the request for proposals warned offerors that continuous compliance with all material aspects of the solicitation, including regulatory requirements, was necessary to be eligible for award.

After evaluating proposals, the Navy determined that the proposal by Silas Frazier Realty, LLC (SFR) was the lowest-priced technically acceptable offer and should receive award. Prior to making award to SFR, the Navy reviewed SFR’s SAM registration and confirmed that it was “active.”

One of the disappointed offerors, TLS, filed a GAO bid protest alleging that SFR was ineligible for award because it had not maintained a continuous SAM registration from the submission of its proposal through contract award. The Navy defended its award decision by arguing that FAR 52.204-7 does not require continuous registration but only requires a firm to be registered at the time of proposal submission and when any contract is awarded.

FAR 52.204-7(b)(1) requires that, to receive an award, an offeror must:

be registered in SAM when submitting an offer or quotation, and shall continue to be registered until time of award, during performance, and through final payment of any contract, basic agreement, basic ordering agreement, or blanket purchasing agreement resulting from this solicitation.

On review of this provision, GAO ultimately agreed with TLS that FAR 52.204-7 “plainly and unambiguously requires offerors to maintain their SAM registrations during the evaluation period.”2 In making this finding, GAO rejected the Navy’s reliance on regulatory history suggesting that perhaps offerors only needed to be registered in SAM at the time of award. On this point, GAO explained that it will only consider regulatory history as an interpretive aid when the regulation is ambiguous.

After finding that FAR 52.204-7 requires continuous SAM registration, GAO turned to the question of whether SFR’s SAM registration actually lapsed. GAO explained that the regulation required both the offeror and the government to take actions for an offeror to be considered registered in SAM. Specifically, the offeror must enter all mandatory information, and the government must validate the information and mark the record as “active.”

Turning to the facts of the case, GAO found that SFR’s registration expired on December 11, 2023, and was not activated by the government until December 12. GAO explained that even though SFR submitted its SAM renewal request on December 8, the government did not take its required actions until after SFR’s existing SAM registration had expired.

Based on GAO’s conclusion that SFR did not maintain continuous registration in SAM between proposal submission and award of the contract as required by FAR provision 52.204-7, GAO recommended that the Navy terminate the award to SFR and make a new source selection decision.


  • While federal contractors are surely aware of the requirement to be registered in SAM prior to contract award, the GAO’s TLS Joint Venture decision clarifies that the registration must be maintained from the time of proposal submission through the date of contract award.
  • Importantly, the TLS Joint Venture decision shows that any lapses in SAM registration during the relevant period will render the offeror ineligible for award.
  • The GAO’s decision is consistent with a recent US Court of Federal Claims (COFC) decision finding that the plain language of FAR 52.204-7 requires offerors to maintain their SAM registrations without lapses during the solicitation period. See Myriddian, LLC v. United States, 165 Fed. Cl. 650 (2023). Thus, GAO and COFC appear to be aligned on this issue (at least for now).
  • This decision shows that even if an offeror submits a SAM registration renewal request before the expiration deadline, that offeror will suffer the consequences if the government does not validate the information and activate the offeror’s account in time. This application of a strict liability standard may strike offerors as a harsh and somewhat unfair result.
  • In this case, the offeror submitted its renewal a mere three days before the expiration date, and no facts suggested that the government unduly delayed its processing of the request. It is unclear whether GAO would reach the same result in a situation where the government was to blame for failing to renew an offeror’s SAM registration within a reasonable time or otherwise was at fault for the registration lapse.

Federal contractors may reasonably complain that GAO’s TLS Joint Venture imposes an unduly harsh consequence when a contractor submitted its SAM information before its registration expired and the registration lapse only lasted one day. That said, GAO and the COFC appear to be aligned in their interpretation of FAR 52.204-7. Accordingly, contractors should take note of the TLS Joint Venture decision, which provides a stark warning that small administrative matters like SAM registration can make the difference between receiving a contract award and being disqualified.

1 TLS Joint Venture, LLC, B-422275, Apr. 1, 2024, 2024 WL 1460853.

2 Id. at 3.

Healthcare Spotlight: House Considers Banning Biotech from China 

On Wednesday, May 15, the House Committee on Oversight and Accountability held a markup to consider multiple bills including the BIOSECURE Act. An updated draft of the BIOSECURE Act was released last Friday, May 10. The bill would prevent the Federal Government from purchasing equipment or contracting services from WuXi AppTec, WuXi Biologics, and other “’biotechnology company[ies] of concern.’” It would also ban Federal agencies from purchasing from contractors that use equipment from these biotechnology companies of concern. In addition to banning new agreements, the bill would prevent firms from extending, renewing, or entering into agreements that would require a different firm to use equipment in the performance of a contract from these companies and require all existing contracts to end by January 1, 2032.   

“This bipartisan, bicameral bill prevents U.S. tax dollars from flowing to biotechnology companies that are owned, operated, or controlled by China or other foreign adversaries,” said Chairman Comer (R-Ky.). “This bill is a necessary step towards protecting America’s sensitive healthcare data from the CCP before these companies become more embedded in the U.S. economy, university systems, and Federal contracting base.” 

The House Oversight Committee also considered H.R. 5255, the Federal Contractor Vulnerability Elimination Act of 2024 which requires the Office of Management and Budget to recommend updates to the Federal Acquisition Regulation (FAR) to ensure that covered Federal contractors have Vulnerability Disclosure Programs consistent with standards developed by the National Institute of Standards and Technology. 

View from Main Street: Size Protests under Unrestricted Multiple Award Contracts

Updates on Timely Topics Impacting the Government Contracting Industry from the Coalition’s Vice President of Acquisition Policy, Ken Dodds

A few weeks ago, I wrote about a size appeal called Forward Slope, where the Small Business Administration’s (SBA) Office of Hearings and Appeals (OHA) reversed the Area Office and found that a firm was eligible for award of a task order set aside for small business under the Seaport NxG multiple award contract (MAC), even though the firm was other than small at the time of offer for the order (November 29, 2022).[1] I thought that under SBA’s rules in effect at the time the solicitation for the order was issued, size for orders set aside under unrestricted MACs (not including the Schedule) would be determined at the time of offer for the order.[2] Although not discussed in the Forward Slope decision, some recent OHA decisions explain the confusion.

Apparently, offerors did not submit pricing with their offers for the Seaport NxG MAC. Prior to May 30, 2023, SBA’s rules essentially provided that for MACs where price was not required as part of the initial offer, size would be determined at the time of the initial offer for the contract.[3] Although there was not a policy reason to distinguish between MACs that included price with the initial offer and those that did not for purposes of eligibility for set aside orders under unrestricted MACs, SBA did not correct this oversight until a final rule effective May 30, 2023, which provided that the rule applied to solicitations issued on or after the effective date.[4] Thus, In a recent size appeal involving a set aside order under Seaport NxG, OHA reversed the Area Office and found the appellant to be a small business because the regulations in effect at the time the solicitation for the order was issued (September 14, 2022) did not require firms to be small at the time of offer for set-aside orders under unrestricted, unpriced MACs.[5] OHA did state that the May 30, 2023, rule change would apply to small business set-aside order solicitations issued after May 30, 2023, under Seaport NxG or other unpriced, unrestricted MACs. OHA also reversed the Area Office with respect to its determination that the appellant was required to recertify its size for the contract because of a change in control.[6] Although the ownership interest in the appellant by an Employee Stock Ownership Plan had increased over time, an individual retained a majority controlling interest throughout that period. Further, while size recertification may be required because of an acquisition, merger or change of control for purposes of counting the dollars awarded under the contract toward the agency’s small business goals, that does not necessarily require recertification in connection with orders under the contract. In a subsequent size appeal involving two orders set aside for small business under Seaport NxG, OHA granted the appeal and remanded to the Area Office because the solicitations for the orders were issued prior to May 30, 2023.[7]

[1] Size Appeal of Forward Slope, Inc., SBA No. 6258 (2023).

[2] 13 CFR 121.404(a)(1)(i)(A), (a)(1)(ii)(A).

[3] 13 CFR 121.404(a)(1)(iv) (2022).

[4] 88 FR 26164; 13 CFR 121.404(a)(1)(iv).

[5] Size Appeal of Imagine One Technology & Management Ltd., SBA No. SIZ-6271 (2024).

[6] 13 CFR 121.404(g)(2)(i).

[7] Size Appeal of McLaughlin Research Corporation, SBA No. SIZ-6273 (2024).

Off the Shelf: The Federal Government’s Cybersecurity Framework 

Bob Metzger, Shareholder at Rogers Joseph O’Donnell, joined Off the Shelf for a discussion on the Federal Government’s cybersecurity framework. During the interview, Metzger outlines the complex, ever-changing threat environment facing government and industry. He also analyzes the government’s underlying cyber strategy currently being implemented through procurement regulation and gives his take on the FAR’s cybersecurity regulations/clauses and the Department of Defense’s Cybersecurity Maturity Model Certification (CMMC) program. Finally, he shares his thoughts regarding the impact of the cyber regulatory framework’s impact on small businesses.  

Listen to the full podcast here

Webinar: False Claims Act Update for Government Contractors, June 6      

The Department of Justice (DOJ) and qui tam whistleblowers continue to actively pursue enforcement actions against government contractors under the Civil False Claims Act (FCA), presenting heightened risks to contractors subject to an increasingly complex array of compliance obligations in fast-changing areas such as cybersecurity. On June 6 from 12:00 – 1:00 pm (ET), Perkins Coie Partners Alexander Canizares and Barak Cohen will provide an overview of the FCA enforcement landscape in 2024 with a focus on developments relevant to commercial contractors. 

Drawing on their experience handling FCA investigations and litigation as well as mandatory disclosures, Alex and Barak will address DOJ’s procurement fraud enforcement priorities, including its Civil Cyber-Fraud Initiative focusing on using the FCA to redress non-compliance involving cybersecurity and the implications of FCA enforcement for contractors facing new and emerging programs such as DoD’s cybersecurity assessment initiative. The presentation will also address DOJ efforts to incentivize companies to self-disclose non-compliance as well as cooperate in DOJ investigations. They will also address the latest developments related to DOJ’s use of the FCA to pursue fraud involving the Paycheck Protection Program (PPP) and pandemic-related loans. 

To register, click here

VA Data for Healthcare Members 

To increase the number of valuable tools available for members, the Coalition has compiled several data sets pertaining to VA Medical Centers’ procedures, diagnoses, and product spend. Below is a description of the different VA data reports that the Coalition can provide to healthcare members based on areas of interest to their business:    

  • Diagnosis data by each VA Medical Center: Members can request a report by providing the relevant International Classification of Diseases (ICD)-10 codes of interest to their business.   
  • Procedure data by each VA Medical Center: Members can request a report by providing the relevant Current Procedural Terminology (CPT) codes of interest to their business.   
  • Prosthetic (medical implants, DME) product spend by VA Medical Center: members can request a report by providing the relevant Healthcare Common Procedure Coding System (HCPCS) codes of interest to their business for items managed by VHA Prosthetics.   

For any data requests or related questions, please contact Michael Hanafin at 

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