Friday Flash, 06.06.14

FAR and Beyond Blog

At least 10 firms filed Government Accountability Office (GAO) bid protests this week against the six month extension of the strategic sourcing Office Supply (OS2) Blanket Purchase Agreements (BPAs).   GSA had extended the OS2 BPAs for a six month term beyond the original five year period.  The intent of the extension was to provide BPA coverage until the OS3 IDIQ contracts are awarded this fall.  Under the bid protest rules, OS2 BPA performance must be suspended pending resolution of the bid protests unless the government makes a written determination to continue performance.  As a result, there is currently no Federal Strategic Sourcing Initiative (FSSI) vehicle in place for office supplies.  Office supplies are available through the GSA Schedules program.

The office supply strategic sourcing initiative is the canary in the coal mine.  It highlights the distortion of the federal market place being wrought by FSSI. Perhaps it is time for a “pause and reflect” regarding the Office of Management and Budget’s (OMB’s) cross-cutting, top down, centralized approach to strategic sourcing.  With that in mind, some reflections on the federal market and strategic sourcing:

• Effective accomplishment of critical agency missions must be the government’s first priority.
• One size does not fit all.  Department and agencies have varying missions.  The variety of roles and functions across government translate into different mission support needs, funding profiles, technical requirements, governing regulations and cultures.  There are good reasons why agencies buy differently—their organizational circumstances are unique to their mission.
• Strategic acquisitions must consider total cost.  Award price alone is incomplete data.  Price as a primary measure of success ignores the costs associated with creating and managing the FSSI infrastructure across the federal enterprise.   It also ignores contract terms that drive pricing.
• Clear requirements and volume commitments are the keys to increasing best value outcomes for customer agencies.   The closer the procurement is to the requirements, the better chance for a sound outcome.  That is why the Coalition has consistently supported the use of agency specific BPAs as a strategic acquisition approach.  Agency specific BPAs provide a sound platform for volume commitments and clear statements of work.
• The federal market is large and significant, however, the federal government is not always the “largest buyer”.  In reality, for traditional commercial firms the federal government may account for only a fraction of a percent of total sales.  As such, the Government can increase efficiency and reduce costs by reducing the number of Government unique requirements in its FSSI.
• Reducing the contractor base can cause real harm to the long term health of the federal market.  For example, FSSI has closed the office supply market to small businesses.  Large businesses are not immune.  For example, the current strategy for the follow on OS3 procurement is to award to only one large business.  It is not in the interests of a strong, vibrant supply chain to limit the federal office supply market to one large business and a limited number of small businesses.
• There are some commercial markets where centralized strategic sourcing may make sense.  GSA has had success with its overnight delivery strategic sourcing initiative.  Similarly, GSA’s FSSI Wireless BPAs have seen positive results.  What do these programs have in common?  First, each has a limited number of competitors in the commercial market.  Second, all the key competitors received an award and the subsequent opportunity to compete for task orders.   Third, GSA has developed a set of best practices and tools to assist agencies in managing requirements. GSA is on the right track in areas where it is developing best practices guides and providing acquisition support for customers of it GSA Schedules and GWAC programs.

It is time for a “pause and reflect.”  Government and its private sector stakeholders have an opportunity to structure strategic acquisition reform that focuses on agency specific requirements, enhances competition, creates opportunities, supports innovation, and maintains a healthy vibrant commercial supply chain.  It is time for a Myth-Busters dialogue on FSSI with OMB and the Strategic Sourcing Leadership Council.

 

Roger Waldron

President

 

Utah, Omaha, Gold, Juno, and Sword: The Beaches of Normandy on June 6, 1944

Today marks the 70th Anniversary of D-Day—the day when the Allies launched Operation Overlord, the campaign to liberate Europe. Democracy, liberty and the fate of Western Civilization hung in the balance.  Here is Supreme Allied Commander General Dwight D. Eisenhower’s message to the soldiers, sailors and airmen of the Allied Expeditionary Force:

 Soldiers, Sailors and Airmen of the Allied Expeditionary Force!

You are about to embark upon the Great Crusade, toward which we have

striven these many months. The eyes of the world are upon you. The

hopes and prayers of liberty-loving people everywhere march with you. 

In company with our brave Allies and brothers-in-arms on

other Fronts, you will bring about the destruction of the German war

machine, the elimination of Nazi tyranny over the oppressed peoples of

Europe, and security for ourselves in a free world. 

 

Your task will not be an easy one. Your enemy is well trained, well

equipped and battle hardened. He will fight savagely. 

But this is the year 1944! Much has happened since the Nazi triumphs of

1940-41. The United Nations have inflicted upon the Germans great defeats,

in open battle, man-to-man. Our air offensive has seriously reduced their

strength in the air and their capacity to wage war on the ground. Our Home

Fronts have given us an overwhelming superiority in weapons and munitions

of war, and placed at our disposal great reserves of trained fighting men.

The tide has turned! The free men of the world are marching together to

Victory!

 

I have full confidence in your courage and devotion to duty and skill in

battle. We will accept nothing less than full Victory!

Good luck! And let us beseech the blessing of Almighty God upon this great

and noble undertaking.

SIGNED: Dwight D. Eisenhower

Please take a moment today to remember those who made the supreme sacrifice for us.  Take a moment to remember, appreciate and thank the Veterans of D-Day; the Veterans of World War II.  They saved the world.

 

GSA Tour with PBS Assistant Commissioner Bart Bush

This week the Federal Buildings Committee had the opportunity to tour the GSA headquarters building in Washington, DC with Assistant Commissioner Bart Bush of the Public Buildings Service.  Mr. Bush leads the Office of Client Solutions that develops strategic relationships with Federal agencies and crafts innovative workplace solutions that meet their needs.  Prior to the tour, Bart Bush spoke with members about the Consolidation Fund project in which GSA is working with 19 Federal agencies to consolidate their offices into a federally owned space.

He also addressed GSA’s Furniture and IT (FIT) program that assists customer agencies in the transition to a more mobile and efficient workspace.  It was a unique opportunity for members to discuss these initiatives with PBS leadership and also see the transformative innovations that GSA has adopted within their own agency to save taxpayer dollars.  The Federal Buildings Committee sincerely appreciates Mr. Bush for sharing his time and expertise with the Coalition.  Members who would like a copy of the materials from the meeting, please contact Aubrey Woolley at awoolley@thecgp.org.

 

 

Defense Authorization Amendment Focuses on FSSI

An amendment has been added to the National Defense Authorization Act (NDAA) for FY 2015 that requires a study of the government’s Federal Strategic Sourcing Initiative and its impact on the small business industrial base. The FY 2015 NDAA recently passed the House of Representatives on May 22. The study, which is required to begin by the end of FY 2015, would examine each North American Classification System (NAICS) Code assigned to a contract awarded for small business issues including:

• The number of small business concerns participating as prime contractors prior to the award of the FSSI contract.
• The number of small business concerns participating as prime contractors after the award of the FSSI contract.
• The number of small business concerns anticipated to be participating as prime contractors at the time that the FSSI contract expires.

The study would assess the affect of any changes between the numbers on the health of the small business industrial base and the sustainability of any savings achieved through a FSSI contract. The amendment requires the Comptroller General to report to the House and Senate Small Business Committees within a year of the study’s initiation. If necessary, the report will make recommendations on how to mitigate any negative effects on the small business industrial base or the sustainability of savings.

 

OASIS Faces Bid Protests

The General Services Administration (GSA) is facing five bid protests against its OASIS Unrestricted contract, according to documents filed with the Government Accountability Office.  Companies that have filed protests are:

• Phacil Inc.
• Smartronix Inc.
• VSE Corporation
• American Systems Corporation
• Logistics Management Institute
• Aljucar, Anvil-Incus & Company

 

Hashmi Named GSA CIO

Sonny Hashmi has been named the Chief Information Officer at the General Services Administration, after serving as acting CIO for the past few months. In an email to FedScoop, Hashmi confirmed the appointment, although the GSA has not made an official announcement.

Hashmi is a well-known member of the federal information technology community and has played a key role in recent GSA modernization and implementation efforts at the agency.

 

Women-Owned Businesses Keep Share of Contract Dollars

Despite a declining budget, women-owned businesses are maintaining their share of federal contracting dollars, the Washington Post reports.  Based on reported spending since FY2010, these businesses have maintained approximately 4 percent of the federal contracting market share.  In addition, about 80 percent of contract dollars are held by the combined efforts of women-owned small businesses (WOSBs) and economically disadvantaged, women-owned small businesses (EDWOSBs).  Additionally, contracts being awarded to women-owned firms are concentrated in program management, logistics, administrative support and other professional services while architecture, engineering and construction industry reported a steep decline.  Professional services contract spending to women-owned businesses saw a 3.8 percent increase in FY 2013 while architecture, engineering and construction dropped 50 percent from fiscal 2010 to 2013.

 

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.

 

Cap on Executive Salary Expanded to DoD, NASA Contractors

On May 30th, the Federal Acquisition Regulatory Council issued its final rule on capping executive salary reimbursement rates to now include contracts awarded by DoD, NASA and the Coast Guard. The expanded reach of this compensation cap will retroactively apply to contracts awarded after December 31st, 2011 in compliance with section 803 of the National Defense Authorization Act for Fiscal Year 2012.

 

GAO Report on Cyber Incidents

A recent Government Accountability Office (GAO) report concludes that agencies need to improve cyber incident response practices. The report found that agencies did not effectively or consistently demonstrate actions taken in response to a breach in about 65 percent of reported incidents. In the study, GAO examined the responses of 24 major executive branch agencies compared to a sample of security incidents reported in FY 2012. GAO concluded that agencies lacked a framework of policies and procedures regarding cyber incident reporting. The report comes as there was a significant rise in the number of incidents reported to the United States Computer Emergency Readiness Team (US-CERT) in FY 2013 (see chart below).

Additionally, the lack of clear definitions of roles and responsibilities within an agency contributed to the failure to demonstrate incident response. Only two of the agencies studied had a responsibility structure in place.

GAO recommended that OMB and DHS address incident response practices government-wide, particularly in CyberStat meetings with agencies; to the heads of six agencies to strengthen their incident response policies, plans, and procedures; and to DHS to establish measures of effectiveness for the assistance US-CERT provides to agencies.

 

EPA OIG: Poor Management of T&M Contract Creates Risk, Waste

In a new report issued by the Environmental Protection Agency’s Office of Inspector General, the EPA determined that it lacks a process to verify that contractor personnel have the necessary skill level to satisfy all contract requirements. The OIG reviewed task order 25 on a T&M contract, EP-W-07-067, and found numerous issues regarding documentation of the contractor’s personnel skills. This led to multiple funding increases on the task order, yet not all deliverables were met when the task order was closed. The OIG recommends measures to improve agency oversight of contractor personnel on T&M contracts, but issues still remain in regards to EPA implementation of these measures.

 

NASA SEWP to join IT/Services Committee, June 10

Next week, Darlene Coen of the NASA SEWP program office will join the IT/Services Committee to discuss the recently announced Federal Strategic Sourcing Initiative for desktop and laptop computers. The meeting will be held at Northrop Grumman Information Systems in McLean, VA on Tuesday, June 10 at 10am. To attend, please RSVP to Roy Dicharry at rdicharry@thegcp.org.

 

Two-Part Webinar Series for GSA Schedule Contractors

The Coalition for Government Procurement, in conjunction with Baker Tilly, is pleased to announce an upcoming Two-Part Webinar Series for GSA Schedule Contractors:

The landscape for GSA Schedule contractors has become increasingly difficult.  Both products and services contractors are facing new challenges as they negotiate new GSA Schedule contracts or administer their existing GSA Schedule contracts.  Pricing, contract terms and conditions, and post-award compliance have all come under the microscope, and contractors must be ready to respond.  This two part series will address some of GSA’s and GSA OIG’s recent focal points so that contractors can consider potential impacts to their business and how they can best prepare.

Part 1: Challenges Facing Professional Services Contractors

Thursday, June 24^th, at Noon EDT

Presented by Jeff Clayton and Jenn Thorson

REGISTER HERE!

A disconnect has always existed between services contracting and the GSA contracting model, but big changes are afoot within GSA that could make the Schedules program even more difficult to navigate.  Topics for discussion include: challenges related to labor category mapping, pricing strategies, CSP-1 disclosures and PRC obligations, GSA’s category management initiative and the push for standardized labor categories.  The pressure that GSA is facing from a pricing perspective and its impact on interactions with professional services contractors will also be discussed.

Part 2: Challenges Facing Products Contractors

Thursday, August 14^th, at Noon EDT

Presented by Jeff Clayton and Steven Brewer

REGISTER HERE!

GSA is facing immense pressure to achieve lower prices for its federal government customers.  This has impacted the government’s negotiation tactics and in turn it has impacted, and will continue to impact, products contractors.  Prices paid data is being tracked and horizontal pricing comparisons are becoming the norm.  Federal Strategic Sourcing Initiatives, an increasingly popular tool for GSA, continue their march across the supply side of the Schedules program.  The presentation will discuss all of this and more, including best practices, so that contractors can prepare themselves to respond to these issues.