Friday Flash 12/20/2024

December 19, 2024

Wishing You Joyful Holidays and a Prosperous New Year!

The Coalition for Government Procurement wishes you a joyful holiday season! As the year draws to an end, we are deeply grateful for the contributions of our members. Your support and dedication have been instrumental in our efforts to “advance common sense in government procurement.”

We hope you take this special time to relax and enjoy the holidays with family, friends, and loved ones. As we move into the New Year, we look forward to collaborating with you to achieve new milestones together.

In light of the Holidays, regular publication of the Friday Flash will resume the week of January 6.

Happy Holidays and best wishes for the New Year!

Wishing OFPP’s Lesley Field a Happy Retirement

The Coalition for Government Procurement would like to extend its warmest congratulations to Lesley Field on her upcoming retirement. We are incredibly grateful her remarkable service to the nation and the acquisition community. With nearly 35 years of government service, including 24 years at the Office of Management and Budget and over 16 years as the Deputy Administrator for Federal Procurement Policy in the Office of Federal Procurement Policy (OFPP), Ms. Field’s career is a testament to dedication, professionalism, and excellence in public service. Her commitment to balanced and thoughtful acquisition policy has set a standard for integrity and innovation in Federal procurement, and her transparent approach has fostered trust and collaboration among industry partners and stakeholders.

“Throughout her distinguished career, Lesley Field has been a steady and calming presence, providing clarity and thoughtful leadership in even the most challenging times,” said Coalition President Roger Waldron. “Her dedication to fostering transparency and collaboration has greatly benefited the Federal procurement community. On behalf of the Coalition, I wish her a well-deserved and fulfilling retirement.”

Government Shutdown Resources for Contractors

As of the writing of this article on Thursday evening, December 19, it remains unclear whether Congress will pass a government funding package before the shutdown deadline of Friday, December 20th at midnight. In light of the current status, the Coalition recommends that prudent contractors review the following list of resources and best practices for Federal contractors in the case that there is a government shutdown.

Government Shutdown Resources: https://thecgp.org/2023/09/14/contractor-resources-for-possible-government-shutdown/

This article was written on December 19th at 6:00pm and describes the status of government funding negotiations on Capitol Hill at that time.

$1,000 Donated to Paws for Purple Hearts Thanks to Member Support

The Coalition is thrilled to announce an additional $1,000 donation to Paws for Purple Hearts, made possible by the enthusiastic participation of our members and guests at the Fall Training Conference. The donation reflects over 100 orders of the “Paws and Refresh,” a special conference beverage available during the networking receptions that received tremendous support.

Paws for Purple Hearts is a remarkable organization dedicated to helping veterans overcome mobility challenges and trauma-related conditions through its innovative canine-assisted therapy. Their work plays a key role in improving the lives of veterans, and we are proud to support their mission. We were thrilled to be joined by Paws for Purple Hearts at the Fall Conference for a special presentation and to learn more about their efforts.

Thank you to everyone who supported this effort by ordering the Paws and Refresh drink at the conference! Due to the generosity of our members and guests, we have been able to raise over $20,000 for Paws for Purple Hearts to date.

Thank You for Joining Us at the Coalition’s Holiday Party!

The Coalition thanks everyone who joined us on Tuesday evening at the Tower Club for our Holiday Party. It was a wonderful evening filled with engaging conversations with friends and colleagues, great food and drinks, and even a short briefing on the latest intelligence on Capitol Hill for contractors. As always, it was a memorable way to close out the year! We are grateful for the opportunity to celebrate with our members and we look forward to working together to advance “common sense in government procurement” in the New Year!

Senate Passes FY25 NDAA

The Hill reports that on December 18, the Senate voted 85 to 14 in favor of passing the $895 billion Fiscal Year (FY) 2025 National Defense Authorization Act (NDAA). The bill passed the House last week in a 281 to 140 vote. It now moves to the President’s desk to be signed. The NDAA includes significant technology-related provisions including mandates to streamline the adoption of artificial intelligence (AI), define and plan the DoD AI workforce, and strengthen the Department’s AI education strategy. The FY25 NDAA also directs DoD to investigate the potential creation of a U.S. military service focused on cyber. Additionally, the bill provides a 14.5 percent pay raise for junior service members and a 4.5 percent pay raise for all service members.

New TDR Data Validations to Begin in January

The General Services Administration (GSA) reports that new data validations for Transactional Data Reporting (TDR) will begin in January 2025. GSA will begin cross-checking transactional data uploaded in some Sales Reporting Portal template fields against companies’ awarded catalog. GSA notes that to avoid receiving a system generated error message (Soft Flag error), the data submitted in those fields must match exactly what is in the awarded catalog. A Soft Flag error will trigger a notice and detailed email with suggested fixes to make before the next transactional data submission. A Soft Flag error is not an automatic rejection of a sales report. GSA provided the following steps for preventing or fixing errors:

Step 1: Check that you’re using the current FAS SRP upload template (V3.0) posted on the https://srp.fas.gsa.gov/ landing page. Trying to upload past templates guarantees an SRP rejection.

Step 2: Use the suggested fix sent from SRP in your next submission. Mismatches generate an email with the subject line “TDR Non-Compliant Submission Data for Contract XXX” – it includes the problem field, the lines and entries flagged, and a suggested fix to use on your next submission. If that doesn’t work, contact tdrteam@gsa.gov and include the information you received about the error, how you tried to resolve it, and what further error info you received.

Step 3: Are you reporting Services? Please check to ensure your reporting SIN allows for Services.

Step 4: If you are reporting Services and receive errors on the Manufacturer Name, Manufacturer Part Number, or UPC fields: Check those fields and remove any data from them. Entering unusable or filler data like “N/A” causes an error notice.

Step 5: Review this Interact post with slides, Q&A and a recap of our August MAS Office Hours about the new TDR data fields and data validation strategy.

GSA will continue to provide updates on the new TDR fields and Data Quality Initiatives through its monthly MAS office hours, quarterly MAS Newsletters and posts in GSA’s MAS Interact community.

White House Publishes 2024 Federal Agency AI Use Case Inventory

Fedscoop reports that on December 18, the White House released the 2024 Federal Agency Artificial Intelligence (AI) Use Case Inventory. According to the Office of Management and Budget (OMB), the Federal AI Use Case Inventory is a “a centralized consolidation of AI use case inventories from across U.S. Federal agencies” that “provides transparency into how Federal agencies are using AI.” In 2024, 27 Federal agencies reported 1,757 public AI uses, which is more than double the number of cases in 2023. The top three categories of uses included mission enabling (internal agency support), health and medical, and government services (includes benefits and service delivery).

The inventories reflect use cases at different stages of the lifecycle, including Initiated, Acquistion and Development, Implementation and Assessment, Operation and Maintenance, and Retired. Most use cases are in the Operation and Maintenance phase. Only use cases that can be publicly disclosed are included in the inventory. Use cases that are sensitive, classified, or fall within the Department of Defense do not need to be publicly disclosed.

White House Releases Federal Technology Impact Report on AI, Cybersecurity, and More

GovExec reports that Office of Management and Budget (OMB) released its Federal Technology Impact Report highlighting advancements in AI, cybersecurity, modernization, and digital service delivery during the current Administration.

Achievements in AI included the Executive Order on the Safe, Secure, and Trustworthy Development and Use of AI issued in 2023, which led to investments in AI and the creation of compliance plans, use case inventories, and training for Federal employees. For cybersecurity, the Administration reported significant progress in securing software, implementing multi-factor authentication, and enhancing monitoring capabilities after the 2020 SolarWinds attack. The 2021 Executive Order on Improving the Nation’s Cybersecurity laid out directives, with over half of Federal agencies having implemented most of them.

The report also recognized efforts in technology modernization, notably the Technology Modernization Fund, which has supported over $1 billion in projects across 34 agencies. For digital service delivery, notable initiatives included the 2021 Executive Order on Transforming Federal Customer Experience and Service Delivery to Rebuild Trust in Government and the 21st Century IDEA Act.

Bipartisan Task Force Submits AI Recommendations to House Leadership

On December 17, the Bipartisan House Task Force on Artificial Intelligence (AI) released its final report with “guiding principles, forward-looking recommendations, and policy proposals to ensure America continues to lead the world in responsible AI innovation.” The report was provided to Speaker of the House Mike Johnson and Democratic Leader Hakeem Jeffries to inform future Congressional policy making on AI.

The bipartisan Task Force consists of 24 members who were tasked with developing a U.S. vision for AI adoption, innovation, and governance. The Task Force collected feedback on prominent AI issues from Federal agencies, industry, civil society, and academia. In total, the report provides 66 key findings and 85 recommendations in areas such as:

Government Use
Data Privacy
National Security
Research, Development, and Standards
Civil Rights and Civil Liberties
Education and Workforce
Energy Usage and Data Centers
Small Business
Healthcare
Financial Services

The Task Force recommends a targeted approach to AI that “balances the need to promote vibrant AI innovation while safeguarding Americans from potential harms as we enter an era of widespread adoption of AI.”

OASIS Program Ordering Period and Award Update

This week, GSA shared the following update on key dates for its OASIS program:

On December 19, the ordering period for OASIS Small business and 8(a) contracts ended.
The unrestricted contract ordering period will end on March 1, 2025.
Acess to Symphony Task Order Management System for the OASIS Small Business, OASIS 8(a) and OASIS Unrestricted contracts will end on February 28, 2025, at 11:59 p.m. (eastern time). Stakeholders must retrieve any needed data from Symphony before this time.

On December 17, GSA announced the first set of rolling award decisions for its OASIS+ Unrestricted contract. The number of companies authorized to participate to date are 588 awardees under the Unrestricted contract. The number of companies anticipated to be authorized to participate by domain follows:

Management & Advisory Services – 398
Technical & Engineering Services – 399
Intelligence Services – 148
Research & Development Services – 154
Logistics Services – 103
Facilities Services – 72
Environmental Services – 52
Enterprise Solutions Services – 29

GSA notes that if an offeror has not been notified of their award status, their offer is still being evaluated as part of the rolling awards process. GSA plans to reopen the OASIS+ solicitations for on-ramping in fiscal year 2025.

SEWP VI Deadline Extended to February 17

On December 16, NASA released Amendment 10 of its SEWP VI Request for Proposal (RFP). Please note the due date of the solicitation is extended to 1:00 PM (ET) on February 17, 2025. In addition, the sixth set of responses to industry questions submitted after May 23, 2024 are now available on the SEWP VI Website.

Please note: The NASA SEWP comment tool, located on the SEWP VI website, is open until 5:00 PM (ET) today, December 20. Interested parties can submit their remaining questions on the RFP through the tool.

View the Alliant 3 RFP Pre-Proposal Conference Video Series

GSA has provided a pre-recorded, pre-proposal conference for the Alliant 3 Request for Proposal (RFP). The pre-proposal conference is issued as a series of videos focusing on specific areas of the RFP. The pre-proposal conference video series includes:

Alliant 3 Proposals are due on February 3, 2025.

Army Issues MAPS Draft Sections L & M

On December 13, the U.S. Army released Draft 2 of Sections L & M of its Marketplace for the Acquisition of Professional Services (MAPS) contract vehicle. Comments are due to the Army on January 13, 2025. The Coalition is collecting feedback on the draft. Interested parties please send your feedback on the draft sections to Michael Hanafin at mhanafin@thecgp.org by January 7.

MAPS is a multiple-award, indefinite-delivery/indefinite-quantity contract that is set to replace the ITES-3S and RS3 contracts in 2027. For additional information on MAPS, please view the links below:

The Coalition has established a MAPS Working Group. To join, please contact Michael Hanafin at mhanafin@thecgp.org.

GSA Provides Updated Instructions on Identifying SUP Free Packaging

GSA has updated an Interact post that explains how suppliers can garner a “Single Use Plastic (SUP) free” icon for products on GSA Advantage! in alignment with the June 6 “Reduction of Single Use Plastic (SUP) Packaging” final rule. This new SUP free packaging icon was created so contracting officers can easily identify and procure the SUP free products they need to meet their agency’s environmental preferable purchasing goals consistent with FAR Part 23. The Interact post is as follows:

Hello Multiple Award Schedule (MAS) Contractors:

GSA finalized the Reduction of Single-Use Plastic Packaging rule, amending the GSA Acquisition Regulation (GSAR). The new rule aims to reduce single-use plastic (SUP) waste by encouraging contractors to state whether they offer SUP-free packaging with a new icon on GSA Advantage!®. The new icon makes it easier for agency buyers to identify and select products that help meet their plastic waste reduction goals. Subpart 502.1 of the GSAR defines SUP free packaging as product or shipping containment materials free of single-use plastic.

Product packaging means brand packaging, sales packaging or primary packaging, which is intended to provide the user or consumer with the individual unit of the product, such as plastic casing. Grouped packaging or secondary packaging means packaging intended to bundle, sell in bulk, brand, or market/display products.

Shipping packaging means packaging that serves as protection for the goods to ensure safe transport to the end customer, including ancillary or redundant packaging. Ancillary packaging, transport packaging or tertiary packaging means packaging intended to secure the product, such as packing peanuts, wrapping materials, or molded materials. Ancillary packaging (or all shipping packaging) is typically outside of brand packaging. Redundant packaging means packaging that does not add any measurable protection to the supply being shipped, such as multiple layers of bubble wrap to an already durable product that is encased in a cardboard box.

Providing SUP-free Packaging

There are two ways to get the SUP-free packaging icons on GSA Advantage!:

SUP-free Packaging can be identified by MAS contractors in their schedule contract. SUP-free packaging includes shipping or product packaging.

Instructions for new offers

Offerors proposing products with SUP-free packaging will complete GSAR provision 552.238-118, Single-Use Plastic (SUP) Free Packaging Identification (July 2024) in the eOffer application. Any costs or savings associated with SUP-free packaging must be included in the proposed product price.

To add the icon to your products on GSA Advantage! after your MAS contract is awarded:

If using the Scheduled Input program (SIP): Use the product or accessories input screen. On the Product Environmental/Special Features screen, select the “Single Use Plastic” (SUP) Free Packaging” option 2.

If using the IMSG import file, use the code “SU” to identify SUP-free products.

If using Electronic Data Interchange (EDI), use the environmental/special feature code “SU” in your catalog file.

Instructions for existing MAS contractors

Contractors must accept Refresh 23, which incorporates the updated GSAR 552.238-88, GSA Advantage!, and adds GSAR 552.238-119, Single-use Plastic (SUP) Free Packaging Availability.

After accepting the mass modification, MAS contractors that provide SUP-free packaging and would like to highlight products on GSA Advantage! with the SUP-free packaging icon must submit a Revise Terms and Conditions modification request in eMod which includes GSAR 552.238-118, Single-Use Plastic (SUP) Free Packaging Identification with fill-ins completed. A Word version of the 552.238-118 provision is available on the Roadmap of Required templates for a MAS offer.

To add the icon to your products on GSA Advantage!:

For FAS Catalog Platform (FCP) participants, submit a Product Descriptive Change Modification combined with the Terms and Conditions Modifications to add the provision in eMod and an associated Change Action in FCP; input code “SU” to the product_info_code field and complete the modification.

For SIP/EDI users, see the instructions above for new offers.

 2. SUP-free Brand Packaging is a new field that can be selected by manufacturers and their authorized partners in the Verified Products Portal (VPP) for applicable products. Identified products will be highlighted with the SUP-free product packaging icon on GSA Advantage!.

Use of the SUP-free Icons

The SUP-free packaging icon is featured on the Strategies to Reduce Plastic in Packaging page on our Sustainable Facilities Tool. MAS contractors that offer products with SUP-free packaging on GSA Advantage! can download the icon and use it on their website. Refer to GSAR 552.238-119 Single-use Plastic (SUP) Free Packaging Availability and the GSA Logo Policy for more information on use of the icon. Once the icon is available in GSA systems, GSA will apply the icon to applicable products on GSA Advantage!. 

Have questions? Contact maspmo@gsa.gov.

Legal Corner: Navigating the COTS Exception in Government Contracts Data Security Requirements: A Closer Look at the FAR and DFARS

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.

Authored by Towsend Bourne, Partner, Sheppard Mullin

In the intricate world of government contracts cybersecurity, understanding the nuances of the Federal Acquisition Regulation (FAR) and the Defense Federal Acquisition Regulation Supplement (DFARS) is crucial for contractors. One area of significant interest and, often, confusion revolves around the commercially available off-the-shelf (COTS) exception and its implications for data security requirements.

Understanding the COTS Exception

The COTS exception refers to a specific exemption within the FAR and DFARS that applies to commercially available off-the-shelf items. COTS items are defined as any item of supply that is (1) a commercial item, (2) sold in substantial quantities in the commercial marketplace, and (3) offered to the government under a contract or subcontract at any tier, without modification, in the same form in which it is sold in the commercial marketplace.

The rationale behind the COTS exception is to streamline procurement processes and reduce the compliance burden on contractors supplying COTS items to the government. With regard to data security, the COTS exception seemingly acknowledges that acquisitions solely for COTS items will not require access to sensitive government information. (In fact, DoD has said, “Procurements solely for the acquisition of COTS items are extremely unlikely to involve covered defense information.” DoD Cyber FAQs.) However, where a COTS provider may be under contract to provide COTS items along with associated services and/or will be provided with sensitive government information, there is a question regarding required data security compliance and whether such procurement truly is “solely” for COTS items.

Data Security Requirements under the FAR and DFARS

The FAR and DFARS establish requirements for safeguarding federal contract information (FCI) and controlled unclassified information (CUI) to prevent data incidents and unauthorized access.

DFARS clause 252.204-7012, Safeguarding Covered Defense Information and Cyber Incident Reporting, for instance, mandates that contractors implement the security controls of the National Institute of Standards and Technology (NIST) Special Publication (SP) 800-171, at a minimum, on internal systems with DoD CUI or controlled technical information (i.e., Covered Defense Information). The provision prescribing use of the DFARS -7012 clause and other DFARS cybersecurity clauses (including DFARS 252.204-7008, -7019, and -7020) states the clause is to be used “in all solicitations and contracts, including solicitations and contracts using FAR part 12 procedures for the acquisition of commercial products and commercial services, except for solicitations and contracts solely for the acquisition of COTS items.” DFARS 204.7304(c) (emphasis added). To date, DoD has not provided specific guidance on how it determines whether a procurement is “solely” for COTS items in this context (i.e., acquisitions for delivery of COTS items along with installation services may not be considered “solely” COTS procurements, particularly if the contactor will be provided with CUI).

Notably, DoD released a final rule on November 15, 2024 to update DFARS 212.371 to add the contract clause at DFARS 252.204-7012, along with other DFARS cybersecurity clauses, to the list of solicitation provisions and contract clauses that are inapplicable to contracts for the acquisition of COTS items. (This list also includes FAR 52.204-21, discussed below.) This should help provide clarity as, with this update, agencies should not include the FAR and DFARS cybersecurity provisions in DoD acquisitions solely for COTS items.

Interestingly, the prescribing provision for inclusion of FAR 52.204-21, Basic Safeguarding of Covered Contractor Information Systems, does not specifically incorporate the COTS exception, but states the contracting officer shall insert the clause “in solicitations and contracts when the contractor or a subcontractor at any tier may have Federal contract information residing in or transiting through its information system.” FCI is a broad category of information and inclusion of this provision requires the contractor to implement 15 basic security controls on its information systems housing such information. However, note the subcontract flow-down subsection in the clause provides the contractor is not required to include the clause in subcontracts for COTS items (FAR 52.204-21(c)).

To the extent the FAR or DFARS clauses are included in an agreement and a contractor believes it is supplying only COTS items, it is best to address this up front with the customer and have the clauses removed, if possible. Importantly, the regulations discussed herein relate to security requirements for contractor internal information systems that process, store, or transmit FCI or CUI. To the extent a COTS provider can work with its customers to ensure it only views sensitive government information by accessing a compliant system maintained by the customer or another third-party, the COTS provider can mitigate risk and may be able to avoid implementing the full set of security requirements on its own internal systems.

The Impact of the COTS Exception on Data Security

The COTS exception can significantly reduce compliance hurdles for contractors supplying COTS products where stringent data security requirements under the FAR and DFARS are not applicable to certain procurements. However, contractors should be careful not to interpret the COTS exception too broadly or as a blanket exemption from all security considerations.

The government maintains a vested interest in ensuring the security of its data, even when dealing with COTS products. Contractors supplying COTS products might consider implementing the basic security controls in the FAR as a best practice (and where the FAR clause is included in contracts, it is possible the government expects compliance with these data security requirements even where the contractor believes it is supplying solely COTS items). Further, where a company needs access to CUI to perform under a contract, there is a serious question regarding whether that contract is solely for COTS items and therefore exempt from implementation of NIST 800-171 controls. Even where it is clear the FAR and DFARS provisions are not applicable, contractors must still adhere to general principles of data protection and may be subject to other requirements not explicitly waived by the COTS exception.

Conclusion

For contractors navigating the complex landscape of government procurement, understanding the boundaries of the COTS exception is key to ensuring compliance while leveraging the benefits it offers. In light of increased scrutiny on contractor False Claims Act liability through the DOJ’s Civil Cyber-Fraud Initiative, it is essential to conduct a thorough analysis of the items being supplied to determine whether they qualify as COTS and to understand the specific data security requirements applicable to each contract. Contractors and subcontractors should be vigilant and proactive in this area to pushback on inclusion of data security provisions, as appropriate, and to clarify where the contractor believes it is supplying solely COTS items and thus should not be subject to the FAR and/or DFARS data security requirements.

View from Main Street: Size Recertification After Offer but Prior to Award

Historically, the length of government contracts did not exceed five years and size was determined at the time of offer (including price) for the contract. With the advent of long-term multiple award task or delivery contracts lasting for ten or twenty years and a focus on data surrounding the Federal Government’s annual small business prime contracting goal achievement, in 2007 the Small Business Administration (SBA) created rules requiring size recertification in certain circumstances.[1] These initial recertification rules were for small business prime contract goal achievement counting purposes and did not mandate actions by the contracting agency or change the terms or conditions of the contract. Of course, a contracting agency could choose not to exercise an option or terminate a contract based on a size recertification or could choose to make size recertification a condition for award of an order, but SBA’s rules did not require it. In 2016, SBA amended the rules to clarify that the requirement to recertify size because of an acquisition or merger applied after offer, but prior to award.[2] Again, SBA’s rules did not require the contracting agency to take any action with respect to the award of contract based on the recertification, but the contracting agency could not count the dollars awarded under the contact towards the agency’s small business prime contract goals. Subsequently, effective November 16, 2020, SBA made a recertification policy change which impacted eligibility for award.[3] If a firm recertifies its size as other than small following a merger or acquisition that occurs within 180 days of an offer, but prior to award, the firm is not eligible for award.[4]

The General Services Administration (GSA) issued the OASIS+ multiple award small business set-aside solicitation on June 15, 2023. A firm submitted an offer on October 20, 2023. On July 10, 2024, the firm informed GSA that it was no longer small because of a merger or acquisition. The firm also stated that the event occurred more than 180 days after offer, rendering the firm eligible for award under SBA’s regulations. GSA declined to award to the firm and the firm filed a protest at the Government Accountability Office (GAO). GAO denied the protest.[5] SBA’s regulations prohibit award where a firm recertifies as other than small within 180 days of an offer. SBA’s rules also allow an agency to award to an offeror that recertifies as other than small more than 180 days after an offer, but do not require the agency to do so. GSA’s decision not to award is consistent with the OASIS+ small business set-aside solicitation/contract clauses which generally provide that if a contractor recertifies as other than small, the contractor can finish performing already awarded task orders, but the contractor will be placed in “dormant” status and will not be eligible to compete for future task orders.[6]

[1] 71 FR 66434.

[2] 81 FR 34243.

[3] 85 FR 66146.

[4] 13 CFR 121.404(g)(2)(iii).

[5] Jefferson Consulting Group, LLC, B-421775.5, Nov. 15, 2024.

[6] Clauses G.3.1.7.3 and H.12 of Solicitation No. 47QRCA23R0001.

Off the Shelf: Procurement Priorities at NASA

Karla Smith Jackson, Senior Procurement Executive and Deputy Chief Acquisition Officer at NASA, joined Off the Shelf to discuss Federal procurement policy and operations.

During the interview, Jackson shared her management priorities for NASA procurement and reflected on how her 30-year career has influenced her approach to acquisition policy development. Jackson emphasized the importance of supporting the acquisition workforce, outlining her philosophy for enhancing professional development across NASA’s procurement team.

She also shared her views on effective leadership, offering insights into what makes leadership successful in the procurement field.

Listen to the full podcast here.

Request for Feedback on Proposed Rule Raising Procurement Thresholds

The Coalition plans to submit comments on a November 29 proposed rule, “Inflation Adjustment of Acquisition-Related Thresholds.” This proposed rule implements a statutory requirement to adjust acquisition related thresholds every five years to account for inflation. Highlights of the rule include:

The micro-purchase threshold at FAR 2.101 will increase from $10,000 to $15,000;
The simplified acquisition threshold will increase from $250,000 to $350,000; and
The prime contractor subcontracting plan (FAR 19.702) floor will increase from $750,000 to $950,000.

The public has until January 28, 2025, to submit comments. To share your input for inclusion in the Coalition’s comments, please email Greg Waldron at gwaldron@thecgp.org by January 18, 2025.

Join a Coalition Committee

Members participate in various Coalition committees to stay up to date on the latest Federal contracting developments for their particular industry and to provide feedback to the government on contracting programs of interest. Committees include:

Business Regulatory Issues Committee (BRIC)
Cyber & Supply Chain Security Committee
Furniture/Furnishings Committee
General/Office Products Committee
Green Committee
GWAC, MAC & Enterprise Committee
Imaging Equipment Committee
Information Technology (IT)/Professional Services Committee
Healthcare Committee
Medical/Surgical Committee
Pharmaceutical Committee
Small Business Committee

Learn more about the Coalition’s committees here. If you are not already on a committee distribution list and would like to sign up, please email Mady Whiting at mwhiting@thecgp.org with which committees you are interested in joining.

2024 Small Business Regulatory Year in Review, Jan. 22

The Coalition is excited to host a virtual 2024 Small Business Regulatory Year in Review presentation on January 22 from 10:00 – 11:30 AM (ET)! The event features industry experts David Black, Partner at Holland and Knight, Ken Dodds, Vice President of Acquisition Policy at The Coalition for Government Procurement, and Jon Williams, Partner at PilieroMazza, who will provide insights on the regulatory cases and updates of the past year that affected both large and small business contractors.

During the event, Black, Dodds, and Williams will cover a wide range of topics, including observations on:

Small Business Administration (SBA) updates
Office of Hearings and Appeals (OHA) cases
Government Accountability Office (GAO)/Court of Federal Claims (COFC) decisions
And More

Small and large businesses are encouraged to attend. If you have any questions in advance of the event, please contact Joseph Snyderwine at Jsnyderwine@thecgp.org.

To register, click here. For assistance with registration, please contact Madyson Whiting at MWhiting@thecgp.org.

Webinar – US Army MAPS: Steering Your Proposals to New Heights, Feb. 6

Please join the Coalition as we host Baker Tilly’s Leo Alvarez, Principal, and Dylan Schreiner, Senior Manager, on February 6 at 12:00 PM (ET) for a webinar, US Army MAPS: Steering Your Proposals to New Heights.

The Department of the Army has reimagined its acquisition approach by consolidating ITES-3S and RS3 into a unified, efficient contract vehicle: the Marketplace for the Acquisition of Professional Services (MAPS). With an impressive $50 billion ceiling over 10 years, MAPS is one of the most sought-after federal contracts for FY 2025. By eliminating duplication, MAPS streamlines the acquisition process for knowledge-based professional services, including IT, and aims to enhance how federal contractors support agency missions, driving results. With two draft RFPs released to date, this eagerly awaited contract is expected to spark intense competition among leading industry players.

Baker Tilly is one of the largest government contractor advisory practices in the nation and offers extensive experience in guiding contractors through the MAC proposal process. Don’t miss this opportunity to hear from the experts on maximizing your contract award potential!

To register, click here. For assistance with registration, please contact Madyson Whiting at MWhiting@thecgp.org