Over the course of the last week, the General Services Administration (GSA) issued and received comments on a draft Ascend Blanket Purchase Agreement (BPA). This BPA seeks to assist agencies in their efforts “to develop and implement enterprise-level cloud acquisition strategies through a modernized and simplified approach to meet their IT and cybersecurity requirements.” It is envisioned to provide baseline requirements for capabilities offered by commercial Cloud Service Providers (CSPs) that, currently, are not available under the GSA Multiple Award Schedule (MAS) or Governmentwide Acquisition Contracts (GWACs).
At the outset, Coalition members continue to express their appreciation for GSA’s collegial outreach to industry on this effort. The agency’s commitment to engagement and direct input is welcome as both Government and industry seek to achieve the best solutions delivered most efficiently to agencies seeking to serve the public. Coalition members, however, also remain perplexed regarding the business case for the multi-agency BPA.
As set forth in this blog commentary on a previous iteration of the BPA, which cited Coalition comments responding to GSA’s Request for Information (RFI) for its (GSA) Multiple Award Blanket Purchase Agreement (BPA) for commercial Software-As-A-Service (SaaS), Platform-As-A-Service (PaaS), and Infrastructure-As-A-Service (IaaS), members remain concerned that these efforts, collectively, prompt unnecessary duplication and increased costs. To the point, generic, government-wide multiple award BPAs create redundancy in administrative processes and contract terms, which, in turn, increase costs for contractors, agencies, and GSA because they neglect to identify two salient points required for contractors to submit responsive proposals: who is using the services, and how much will they use.
This point is recognized in Federal Acquisition Regulation (FAR) 8.405-3(a)(6). By providing that the
[e]stablishment of a multi-agency BPA against a Federal Supply Schedule contract is permitted if [that] BPA identifies the participating agencies and their estimated requirements at the time the BPA is established,
this section highlights that generic, government-wide BPAs, like Ascend, that do not include agency requirements simply do not provide an adequate basis for competition. They are not consistent with the Competition in Contracting Act (CICA) and the underlying authorities for the MAS program, and they do not provide industry partners with the critical competitive business information necessary for them to decide whether to compete for the BPA.
The identification of participating agencies and their estimated requirements is especially important in connection with commercial cloud services. These services utilized on an enterprise-wide basis by a given agency likely will have to be customized to meet the agency’s specific requirements, resulting in a large variation in the ultimate delivery format and construct of cloud service offerings provided across agencies. For this reason, leveraging the FAR 8.4 competitive task order process, which calls for the utilization of specific evaluation criteria associated with unique agency requirements, would provide a sound approach to supporting specific customer agency requirements. This approach affords commercial cloud contract holders the opportunity to propose custom solutions responsive to individual agency requirements, avoiding wasteful administrative activity associated with a generic BPA.
To this very point, just last week, the Department of Treasury (Treasury) issued a Request for Quote (RFQ) for its Department of Treasury Cloud (TCloud). In that RFQ, Treasury set forth specific requirements, to which, contractors will respond. Those requirements are tied to specific Treasury needs under “a hybrid Firm-Fixed Price (FFP) and Labor Hour (LH) single-award [BPA] under the [GSA MAS] program, for [TCloud].” Treasury’s BPA is an example of a customer agency leveraging its requirements through GSA’s MAS program.
Along these lines, the Ascend RFI continues to include the requirement that the eventual BPA holders submit competitive proposals 75 precent of the time during the single period of performance. See Section 6.16 (page 31 of the RFI). This term amounts to a procurement tax on both BPA holders and customer agencies. For BPA holders, it demands that they spend valuable, and limited, bid and proposal dollars on the act of submitting responses to task orders that are not justified by a business case, and thus, are not suitable for them to pursue. In turn, customer agencies will be spending valuable time, talent, and other resources evaluating proposals from firms not interested in doing the work. Most significantly, the term creates inaccurate competition data providing a distorted picture of the level of task order competition under the BPA.
As the Coalition noted,
Coalition members believe task order competition directly against the underlying MAS contracts for agency-specific cloud requirements is a more efficient and effective approach than through generic, government-wide BPAs for cloud services. GSA already has the cloud marketplace. It also has the MAS program’s contracts for cloud services. Generic, government-wide BPAs do not leverage the cloud marketplace; task order competitions for agency requirements do.
If GSA continues on the path to securing an Ascend BPA, it will be incumbent on the agency to provide a fulsome business case to its industry partners, including estimated requirements, in order to promote effective competition that delivers best value solutions. To the extent GSA contemplates a deviation from the requirements of FAR 8.404-3(a)(6), it would be admitting, in effect, that there are no customer agency commitments to use the BPA. As such, it will yield a costly, inefficient outcome for its customer and contractor partners.
White House Announces $8 Billion Investment in Climate Smart Buildings Initiative
On August 3, the White House released its Climate Smart Buildings Initiative to modernize Federal buildings and reduce greenhouse gas (GHG) emissions. The Administration plans to achieve these goals through an $8 billion investment in energy savings performance contracts by 2030. According to a White House fact sheet, the initiative is “expected to increase investments from performance contracts from a low of $251 million in FY2021 to a sustained $1.2 billion per year by 2030, a fivefold increase.” Specifically, the Administration is targeting investments in on-site clean energy generation and clean energy technologies like heat pumps, efficient lighting and installation, and electric vehicle supply equipment. As part of the initiative, Federal agencies will also establish emissions reductions targets that will be measured and tracked. Federal agencies, like the General Services Administration (GSA), have already utilized performance contracts to achieve significant energy savings consistent with the President’s Sustainability Plan. For example, GSA awarded an energy savings performance contract in 2021 to modernize six Federal buildings in the Washington, DC area. The project is expected to reduce energy consumption by 42% and “cut 20,000 tons of annual GHG emissions.” Additional case studies on Federal energy performance contracts are available at the Federal Energy Management Program case studies webpage.
On July 27, GSA’s Office of Inspector General (OIG) issued an audit on the use of the 4P Tool by the Federal Acquisition Service (FAS) when performing price analyses for Multiple Award Schedule (MAS) contracts. The 4P Tool was developed by FAS to help the organization “evaluate proposed pricing on MAS contracts offering products”. FAS personnel use the tool to determine fair and reasonable pricing determinations. However, the OIG found that FAS employees lack guidance and oversight regarding their use of the tool. According to the OIG, this has led to frequent pricing decisions that do not comply with the Federal Acquisition Regulation, FAS policy, and the Competition in Contracting Act of 1984. Additionally, the OIG is concerned that this leaves Federal agencies at risk of overpaying for products on MAS contracts, as well as the possibility of taxpayer dollars being misused. Specifically, GSA OIG found the following misuses of 4P:
- Improper reliance on the 4P Tool to establish price reasonableness without conducting additional price analysis;
- Awarding proposed pricing based on a 4P Tool comparison to the current pricing on the same contract, known as self-hits;
- Awarding proposed pricing based on a 4P Tool comparison to other government pricing, despite the 4P Tool identifying better commercial pricing; and
- Awarding pricing that either exceeded the market thresholds established by the 4P Tool or for which the 4P Tool found no market research comparisons, without any further justification or analysis.
GSA OIG gave the following recommendations to the FAS Commissioner to address these issues:
- Develop and implement oversight controls to ensure contracting personnel adhere to FAS Policy and Procedures 2020-02 and 2021-05, and only use the 4P tool as part of a larger negotiation strategy that seeks the lowest overall cost alternative to meet the needs of the Federal Government, as required by the Competition in Contracting Act of 1984.
- Update the 4P Application User Guide to require contracting personnel to:
- Conduct additional price analysis on products for which the 4P tool returns only self-hits;
- Include commercial market pricing information presented in the 4P tool in price evaluations and provide justification when the awarded pricing exceeds the lowest commercial market price found;
- Seek, analyze, and document justification for product pricing that exceeds the market threshold; and
- Manually research an appropriate sample of products for which the 4P tool found no market research comparisons to ascertain applicable market pricing information.
- Provide training to contracting personnel regarding the use of the 4P tool, focusing on updated 4P Application User Guide requirements.
- Develop and implement oversight controls to ensure contracting personnel are following the updated 4P Application User Guide.
- Include commercial market pricing research on the 4P tool overview tab.
- Include “no competitive research found” flags and a competitive research rate in 4P reports, exclusive of self-hits.
- Design and implement procedures to ensure only accurate, current pricing is included in 4P reports.
FAS Commissioner Sonny Hashmi agreed with most of these recommendations.
Senate Passed “Inflation Reduction Act” to Invest in Green Federal Buildings
This week, Federal News Network reported on major investments in climate and other priorities in the Inflation Reduction Act of 2022, passed by the Senate last weekend. The House is scheduled to vote on the bill later today. The $740 billion Senate bill includes funding for Federal agencies governmentwide including the Department of Energy, the Internal Revenue Service, the US Postal Service, and the General Services Administration (GSA). The following are some of the proposed investments:
- For GSA, $2.15 billion for low-carbon materials used in the construction and to upgrade Federal buildings, $975 million for emerging sustainable technologies, and $250 million to convert some existing Federal property to high-performance green buildings;
- For the US Postal Service, $1.29 billion to purchase electric vehicles and an additional $1.71 billion for infrastructure to support the new fleet;
- For the National Park Service and Bureau of Land Management, $250 million to conserve and protect the lands that they oversee; and
- For the Department of Energy, $115 million, some of which would go to “hiring and training personnel and equipment to support environmental review”.
For the full bill text, click here. The Coalition will report on any additional developments next week.
This week, GSA released a report on its Commercial Platforms Initiative. Per Section 853 of the National Defense Authorization Act of FY22, GSA was to conduct additional testing of the online commercial platform models that it originally identified at the launch of the program in 2018. These three models were the e-commerce, e-marketplace, and e-procurement models and were defined as follows by GSA.
- E-Commerce Model: Product vendors that leverage an online platform to sell their own proprietary or wholesale products. The vendor is responsible for the fulfillment of product orders, including invoicing and delivery.
- E-Marketplace Model: Online marketplaces connect buyers with a portal provider’s proprietary products, third-party vendors, or both. Portal providers and third-party vendors are generally responsible for fulfilling orders for their respective products with some exceptions where the portal provider may complete order fulfillment for additional fees.
- E-Procurement Model: E-procurement is a software-as-a-service model that is managed by the buying organization, and often has workflows connecting the internal procurement organizations to financial systems.
GSA conducted an in-depth analysis of these three models utilizing Customer Experience (CX) data and other information, and concluded that-
“…since the original Section 846 and GSA’s initial market research, there has been significant innovation and evolution in this market space. The three models initially identified by GSA have converged, rendering the models themselves outdated and no longer relevant since commercial online providers, regardless of business model, are able to meet the needs and requirements of the GPC cardholder. Thus, utilizing the individual business models as a method for vendor selection and participation in future program contracts is now inconsequential.”
GSA reports that sales under the Commercial Platforms Initiative totaled $11.7 million in FY21 through more than 2 dozen participating agencies and more than 45,000 purchase card holders. They estimate that FY22 sales will surpass FY21. Awardees under the current contract are Amazon Business, Overstock Government and Fisher Scientific. For more information about the program, visit www.gsa.gov/buy-through-us/purchasing-programs/commercial-platforms?gsaredirect=commercialplatforms.
VA Appoints “Functional Champion” for Electronic Health Records Rollout
On August 2, Fedscoop reported that the U.S. Department of Veterans Affairs (VA) has appointed Dr. David Massaro to serve as Functional Champion of the Electronic Health Record Modernization (EHRM) Program. In this role, Dr. Massaro will coordinate the development and implementation of the EHRM Program across the VA. The appointment was announced by VA Undersecretary for Health, Dr. Shereef Elnahal, on Monday. Prior to his appointment, Dr. Massaro served as the Acting Chief Health Informatics Officer for the Office of Community Care within the VHA. He previously held the position of Director of Integrated Health Practice within the VHA’s Office of Health Informatics. He began his career with the VA in 2006. His appointment is the latest position created by the VA to address concerns over the EHRM Program rollout. In late 2021, the VA appointed Dr. Terry Adirim as Program Executive Director of VA’s EHR Modernization Integration Office and Laura Prietula as Acting Deputy Chief Information Officer.
GSA Launches Cyber Supply Chain Risk Management Group on Interact for Government and Industry
In August 2021, the Cyber Supply Chain Risk Management (C-SCRM) Acquisition Community of Practice (ACoP) was launched by GSA and the Cybersecurity and Infrastructure Security Agency (CISA). The goals of the C-SCRM ACoP include broadening awareness and developing “agency maturity in the areas of acquisitions, supply chain risk management, and cybersecurity across the Federal Government for information communication technology and services (ICTS).” Currently, several Federal agencies have limited C-SCRM capabilities, guidance, and training, especially in relation to the acquisition of ICTS. In order to increase both awareness and implementation, the C-SCRM ACoP created a GSA Interact community to serve as a collaborative space for agencies and industry to discuss best practices, guidance, and tools. The C-SCRM ACoP is planning to survey industry in order to identify challenges related to C-SCRM and identify best practices. Monthly sessions are also held for Federal employees in collaboration with CISA that focus on supply chain risk awareness and management, as well as improvements to cyber-acquisitions.
To join the C-SCRM ACoP, email GSA at C-SCRM_ACoP@gsa.gov.
Senate Looks for Alternatives to the Technology Management Fund for FY2023
According to FCW, the appropriations bills released in the Senate in July did not include funding for the Technology Modernization Fund (TMF) because lawmakers are questioning whether it is the best method for funding government-wide initiatives. Instead, the legislation included an increased spending cap for a funding method led by GSA and the Office of Management and Budget (OMB) that would allow Federal agencies to use funds from these agencies for certain IT projects. The increase is from $32 million to $100 million in fiscal year 2023. The Senate version of the appropriations bill changes the language to allow GSA and OMB to fund governmentwide initiatives, particularly tech-related projects, rather than investing in the TMF. The Senate Appropriations Committee made the decision to include this language in the legislation after reviewing a joint IT operating plan from GSA and OMB. This plan included an overview of TMF, GSA’s Federal Citizen Service Fund, and OMB’s Information Technology Oversight and Reform Fund.
In an explanatory statement of the bill, the Committee stated that they were “still concerned that the current funding mechanisms may not be the best way to finance government–wide initiatives.” The statement also explains that the new language would give GSA and OMB access to more resources “to directly invest in government–wide and other multi agency financial, information technology, procurement, and other management initiatives.” The Senate’s funding package differs from the appropriations package passed by the House on July 20 which included $100 million for the TMF.
DoD Uses “Acquisition Pathway” to Streamline Software Purchases
FCW reported on the Department of Defense’s (DoD) Software Acquisition Pathway, which aims to streamline the software buying process by allowing contracting officers and program managers to “separate out the software components of various programs, from unmanned systems to enterprise software.” Radha Plum, who is the Administration’s nominee for the position of Deputy Undersecretary of Defense for Acquisition and Sustainment, said that advancing software modernization through new authorities such as the Software Acquisition Pathway and “matching military needs with technology” are among her top priorities. She emphasized the importance of flexibility and interoperability for DoD’s modern software programs.
The Software Acquisition Pathway, which was launched two years ago, now has 40 programs. A DoD spokesperson stated that within the first two years, the Pathway has shown “encouraging signs that programs can streamline processes and deliver software faster.” The Army’s Chief Weapons Buyer, Doug Bush, reported that they are using the Software Acquisition Pathway to acquire newer software programs and shift older systems to the DevSecOps process, which allows for continuous software development. Bush added that the Pathway will likely be the Army’s top route for new software programs.
Legal Corner: No Summer Break for Cyber: Newly Unveiled CMMC Assessment Process Provides Industry with Upcoming Assessment Insights
The Legal Corner provides the legal community with an opportunity to share insights and comments on legal issues of the day. The comments herein do not necessarily reflect the views of The Coalition for Government Procurement.
After much anticipation, the Cyber AB, formerly known as the Cybersecurity Maturity Model Certification (CMMC) Accreditation Body, recently released its pre-decisional draft CMMC Assessment Process (CAP). The CAP describes the overarching procedures and guidance that CMMC Third-Party Assessment Organizations (C3PAOs) will use to assess entities seeking CMMC certification. The current version of the CAP applies to contractors requiring CMMC Level 2 certification, which will likely be most contractors handling Controlled Unclassified Information (CUI) based on the Department of Defense’s (DoD) provisional scoping guidance for CMMC 2.0.
Aimed at increasing the accuracy and consistency of assessments conducted by C3PAOs, the CAP is segmented into four distinct phases:
Phase 1: Plan and Prepare the Assessment;Phase 2: Conduct the Assessment; Phase 3: Report Assessment Results; and Phase 4: Close-Out Plan of Action and Milestones (POAMs) and Assessment.
While the assessment process is still in draft form, DoD contractors should familiarize themselves with the proposed structure and conduct of CMMC assessments, as these parameters will be critical to companies attaining CMMC certification at the level requisite for future government contract awards.
The Cyber AB is currently accepting comments on the draft CAP.
Legal Corner #2: Recent DoD Memorandum and DoJ Report Highlight Enforcement Mechanisms Available to the Federal Government for Noncompliance with Cybersecurity Requirements
While industry awaits substantive developments on the Cybersecurity Maturity Model Certification (CMMC) 2.0, a recent Department of Defense (DoD) memorandum and the Department of Justice (DoJ) Comprehensive Cyber Review serve as timely reminders of the importance of complying with existing cybersecurity requirements as well as the various mechanisms available to the federal government to enforce compliance.
The principal cybersecurity requirement in the DoD context, and the focus of the DoD memorandum, is Defense Federal Acquisition Regulation Supplement (DFARS) 252.204-7012, Safeguarding Covered Defense Information and Cyber Incident Reporting. Among other things, that clause directs DoD contractors that own or operate an unclassified information system that “processes, stores, or transmits” controlled unclassified information to implement the security controls in National Institute of Standards and Technology (NIST) Special Publication (SP) 800-171. NIST SP 800-171 requires a covered contractor to develop a system security plan (SSP) that describes the information system and explains how the contractor has implemented NIST SP 800-171’s security controls. The contractor must also create a plan of action (POA) identifying any unsatisfied requirements, explaining how it will meet those requirements, and describing how it will mitigate any security vulnerabilities in the meantime. SSPs and POAs are often not formal contract deliverables, but contractors must provide them to the government upon request. In addition, contractors must monitor and timely report cyber incidents. Contracting officers have tools to assess compliance, including requiring assessments in accordance with DFARS 252.204-7020, NIST SP 800-171 DoD Assessment Requirements.
The recent DoD memorandum specifies the above requirements and underscores for contracting officers—and, in turn, industry—the various enforcement mechanisms that the government can utilize to address noncompliance. Specifically, the memorandum notes that a contractor’s “[f]ailure to have or to make progress on a plan to implement NIST SP 800-171 may be considered a material breach of contract requirements” and enumerates available remedies for a breach, including withholding progress payments, declining to exercise contract options, and terminating contracts in whole or in part.
Of course, this is not an exhaustive list of the consequences a contractor may face for noncompliance with cybersecurity requirements. Separate and apart from contract-based remedies, contractors may also face liability under the False Claims Act (FCA). As many will recall, just last year, the DoJ announced a Civil Cyber-Fraud Initiative (CCFI) to utilize the FCA to “combat new and emerging cyber threats to the security of sensitive information and critical systems.” DoJ did not mince words, stating that the CCFI “will utilize the False Claims Act to pursue cybersecurity related fraud by government contractors and grant recipients” and thereby affirming that companies in the federal marketplace are the central focus of this initiative. We have been tracking such cases as they progress through federal courts even before the formal announcement of the CCFI, with settlements now being announced by DoJ.
Earlier this month, DoJ issued a Comprehensive Cyber Review report, which discusses the CCFI, as well as a review that DoJ conducted following the December 2020 breach of its Microsoft Office 365 email environment, which it ultimately traced back to the compromise of SolarWinds’s Orion software. In the report, DoJ affirmed its plans to “lead the effort to enforce cybersecurity requirements on federal contractors and grantees” and further announced its desire to participate in actually developing those requirements. Having found the existing requirements to be “insufficiently rigorous,” DoJ has offered to leverage its enforcement experience to assist the Federal Acquisition Regulation (FAR) Council in developing cybersecurity provisions and standards that are, to DoJ’s judgment, readily enforceable.
DoJ also noted its plan to further integrate “privacy and security terms and conditions” into its own procurement documents, templates, and contracts and, once such provisions are “clear and effective,” to “integrate and deploy a significant number of tools at its discretion to ensure contractual cybersecurity standards are followed.” As with the DoD memorandum, DoJ highlighted contract termination among these tools, but also highlighted its authority to pursue civil enforcement actions (and corresponding monetary penalties) in cases of “reckless or intentional failure to maintain cybersecurity standards.”
With cybersecurity top of mind across the federal government, it remains critical that contractors comply with existing requirements and remain prepared for the forthcoming CMMC 2.0 development. This diligence will come in handy in the event of a contract dispute, investigation or any other enforcement action premised upon allegations of noncompliance.
Off the Shelf: The Shrinking Industrial Base
This week on Off the Shelf, Tom Sisti, Executive Vice President and General Counsel of The Coalition for Government Procurement, shared his thoughts on the shrinking industrial base, including why companies are leaving the market or never entering it in the first place. Sisti explained why this worrying trend will negatively impact government missions, leading to less competition and less access to commercial innovation. He also highlights the demise of commercial item contracting, the role of category management, and the meaning of best-in-class contracts. To listen to the program, click here.
Seeking Member Input on Draft CMMC Assessment Process (CAP)
The CMMC Advisory Board (AB) has released a pre-decisional draft of the CMMC Assessment Process (CAP) for Level 2 for public comment. The CAP is designed to be used by CMMC Third Party Assessment Organizations (C3PAOs) and organizations seeking certification (OSCs). According to the CMMC AB, the CAP “establishes the various phases, procedures, and templates that are employed in the conduct of a CMMC assessment.” The Coalition will submit comments on the draft CAP by August 25 and is interested in hearing from members on the draft. Please send your questions and comments on the draft CAP to Aubrey Woolley at firstname.lastname@example.org by August 15. We will be circulating draft comments for additional member input before the August 25th deadline.
GSA Publishes GSAR ANPR on Reducing Single-Use Plastics and Packaging
On July 7, GSA issued an advance notice of proposed rulemaking (ANPR) seeking public feedback on the agency’s use of single-use plastics, including those used in packaging and shipping of products under GSA contracts as well as items included on the contracts. GSA will use the feedback to establish requirements and reporting mechanisms that will reduce the use of unnecessary single-use plastics. Single-use plastics are defined as plastic materials that are used and immediately disposed of once the product is delivered. The ANPR includes a total of 15 questions in which the agency is seeking feedback, with six related to the economic impact of single-use plastics. Executive Order 14057, Catalyzing Clean Energy Industries and Jobs Through Federal Sustainability, which was issued in December, instructed each agency to “reduce waste to include supporting a recycled content market and circular economy approaches.” In addition to the Federal Supply Schedule, GSA is looking to address single-use plastics in its construction, concession, and facility maintenance contracts. According to the notice, GSA “looks for the most advantageous solutions, remaining ahead of problems before they culminate, and making the best decisions on behalf of the American taxpayer.” The agency is looking to address sustainability in contracts in order to achieve this.
The Coalition is considering submitting comments in response to the ANPR, which are due to GSA on September 6, 2022. We are interested in hearing members’ input on single-use plastics and packaging in products offered under the Schedules and other GSA contracts. Please contact Aubrey Woolley at email@example.com with any feedback or questions that you may have on this topic.
GWAC/MAC Committee Meeting with NASA SEWP, August 23
The GWAC/MAC Committee will be hosting Darlene Coen, NASA SEWP Deputy Program Director and Director of Strategy and Acquisition of NASA on August 23 at 10 am EST. The topic of discussion will be the plans for NASA SEWP VI. Members may attend the meeting in person or virtually.
A couple days in advance of the meeting, all registered members will receive a confirmation email with additional information for those attending in person (e.g., conference room, parking, etc.) and the login for those attending virtually.
If you have any questions, please contact Joseph Snyderwine at JSnyderwine@thecgp.org.
To register click here.
Green Committee Meeting with GSA, August 24
The Coalition is pleased to announce that our next Green Committee meeting will be on August 24 at 1 pm EST. The topic of discussion will be GSA’s Single-Use Plastics and Packaging ANPR and other Federal sustainability developments. Our GSA guest speakers will be Katie Miller, FAS Climate Senior Leader, and Adina Torberntsson, Procurement Analyst/General Services Acquisition Policy Division.
Register here. The meeting is open to members only. All registrants will receive the login information in advance of the meeting.
Small Business Committee Meeting, August 24
The Small Business Committee will host a meeting focused on the Mentor Protégé Program and surrounding regulations on Wednesday, August 24 at 10 am EST. Our guest speakers from the Small Business Administration (SBA) will be John Klein, Associate General Counsel for Procurement Law, Office of General Counsel and Kanika Perkins, Deputy Director of the All-Small Mentor Protégé Program. GSA’s Greg Rollins, Deputy Assistant Commissioner, Office of Policy and Compliance will also brief members during the meeting. This member-only meeting will be held at Holland & Knight at 800 17th St., NW, Washington, DC.
There will also be a virtual option for members to attend.
A couple days in advance of the meeting, all registered members will receive a confirmation email with additional information for those attending in person (e.g., conference room, parking, etc.) and the login for those attending virtually.
To register, click here.
For assistance, please contact Joseph Snyderwine at firstname.lastname@example.org.
Save the Date: Coalition Fall Training Conference, November 16-17
The Coalition is excited to announce that our Fall Training Conference will be held on November 16-17 at the Fairview Park Marriott in Falls Church, Virginia. The conference will once again be a hybrid event so we can accommodate both in person and virtual attendees. We look forward to seeing everyone in the fall and will provide more details as they become available.