Friday Flash 10.01.21

Far & Beyond: Announcing the 2021 Fall Training Conference, What’s Next for the Business of Government? Nov 17-18

The Coalition for Government Procurement (Coalition) is pleased to announce that registration officially is open for our 2021 Fall Training Conference, What’s Next for the Business of Government?  This two-day virtual conference will take place on November 17-18 and will utilize the same technology as our previous two conferences.   

 The Fall Training Conference’s theme will continue the Coalition’s focus on the Biden Administration’s priorities for the federal acquisition system and what it means for government and industry.  We have invited a host of speakers from across the federal acquisition community for a dialogue on key policy, operational, and management initiatives shaping the business of government.   

 Of course, the agenda includes the critically acclaimed Legal Panel announcing this year’s “The Rogers.”  In addition, cyber security and supply chain resilience, Buy America and Buy Allied, safe workplace implementation, the Multiple Awards Schedule consolidation and TDR, the Medical Surgical Prime Vendor program, GWACs, MACs, and more will be covered over the course of two-day virtual training conference.  Here is a listing of just some of the subjects being address in the panels:   

  • Cyber and Supply Chain Compliance 
  • DoD Cybersecurity Initiatives and CMMC 
  • VA Procurement and Contracting 
  • Future of VA Medical Logistics 
  • GSA Interagency Contracting Portfolio Panel (GWACs, OASIS, and More) 
  • Made in America/Buy American and Domestic Sourcing 
  • Medical Supply Chain 
  • Observations from FAS Commissioners – Present and Past 
  • Priorities for IT Modernization Fund 
  • Schedules 
  • View from the Senate 

 As always, both days will conclude with smaller breakout sessions where you will be able to ask your questions directly to the speakers covering topics such as GSA Systems; Office Products; Industrial Products/Update from the SSAC; Services on GSA Schedules; IT; VA PBM; DLA MSPV and ECAT; VA MSPV – Operations; Small Business Opportunities; the e-Commerce Update on Commercial Platforms Initiative; Cloud Marketplace; DHA Pharmaceuticals; GWAC/MAC; Global Supply/4PL; Services MAC; and Furniture! 

 Please click HERE to see the full DRAFT agenda.  

 Please click HERE to register! 

 For sponsorship inquiries, please contact Matt Cahill at mcahill@thecgp.org or 202-315-1054. 

 We look forward to your participation and another great training conference! 

Congress Averts a Government Shutdown

On Thursday, September 30, Congress passed a continuing resolution (CR) to prevent a federal government shutdown, reported Politico. The shutdown would have occurred at midnight on Thursday if Congress did not pass the CR. The House passed the CR with a vote of 254-175 on Thursday afternoon and shortly after the Senate passed the CR with a vote of 65-35. The CR will give Congress until December 3 to pass a budget package.   

The CR addressed the impeding government shutdown, but it did not address the potential default on the national debt, which Democrats originally wanted in the CR. There was also the removal of $1 billion for the Israel’s Iron Dome missile defense system. The Senate voted on three amendments that did not pass before voting on the CR. The Senate voted on an amendment barring the use of federal money to enforce the COVID-19 vaccine mandate; an amendment to prevent Afghan refugees from obtaining REAL IDs; and “no-budget, no-pay” amendment. 

Congress will need to act quickly to avoid default on the national debt. Senate Majority Leader Schumer said he plans to call a vote as early as next week to suspend the debt limit into December 2022. 

COVID-19 Guidance Released for Contractors and Subcontractors 

On September 24, the Safer Federal Workforce Task  Force (“the Task Force”) issued its guidance for Federal contractors and subcontractors on COVID-19 workplace safety. Executive Order 14042Ensuring Adequate COVID Safety Protocols for Federal Contractors, directs executive departments and agencies to ensure that covered contracts include a clause that requires contractors and subcontractors to comply with the Task Force’s guidance.  

While the Executive Order applies to contracts for services, the Task Force guidance “strongly” encourages Federal agencies to also apply the forthcoming FAR clause implementing the guidance into contracts that are not covered by the Executive Order, including “contracts and subcontracts for the manufacturing of products.”  The FAR Council will release the implementing clause for public comment by October 8, 2021.   

In general, the guidance requires the following workplace safety protocols: 

  • Covered contractor employees must be fully vaccinated against COVID-19, except in limited circumstances where an employee is legally entitled to an accommodation. The deadline for full vaccination is December 8, 2021. 
  • Covered contractor employees and visitors must comply with guidance related to masking and physical distancing while in covered contractor workplaces. 
  • Contractors must designate a person or persons to coordinate COVID-19 workplace safety efforts at covered contractor workplaces. 

The order allows for the Office of Management and Budget (OMB) and the Task Force to update the guidance based on future changes to the Centers for Disease Control and Prevention (CDC) COVID-19 guidance and as warranted by the circumstances of the pandemic and public health conditions. 

 

Coalition Submits Questions on Contractor COVID-19 Requirements to GSA

This week, the General Services Administration (GSA) provided industry with an opportunity to share their questions about the Safer Federal Workforce Task Force guidance on COVID-19 Workplace Safety for Federal Contractors. After reviewing the guidance, member questions primarily focused on the scope of covered contracts, the employees that would be covered, what exemptions and accommodations for non-vaccinated employees should be applied, and contract compliance. The member questions that were submitted to GSA are posted here. GSA will reference industry’s questions as they develop their plans to implement the forthcoming FAR clause into GSA contracts. GSA will also host a virtual event on Ensuring Adequate COVID Safety Protocols for Federal Contractors on October 13, described in GSA’s announcement below. 

GSA Industry Event on COVID-19 Safety Protocols for Contractors, October 13 

On Wednesday, October 13 at 1 pm EDT, GSA will host a Virtual Industry Engagement Event on Ensuring Adequate COVID Safety Protocols for Federal Contractors. GSA’s Senior Acquisition Officials will discuss the agency’s implementation of Executive Order 14042 on Ensuring Adequate COVID Safety Protocols for Federal Contractors. Registration for the event is available here. 

 

GAO Report on GSA e-Commerce Pilot and Data Protection  

On September 28, the Government Accountability Office (GAO) released a report evaluating how well GSA is monitoring progress of its Commercial Platforms proof-of-concept and how well the platform providers participating in the program are protecting certain data from unauthorized disclosure and use. The commercial platforms program began in June 2020 with GSA contract awards given to three commercial platform providers—Amazon Business, Fisher Scientific and Overstock Government.  

GSA intended for this program to coexist with the Multiple Award Schedule (MAS) and Global Supply. The program allowed selected agency participants to use their Government purchase cards to make purchases through the three platforms up to the micro-purchase threshold. Thirteen Federal agencies are currently participating in the program: 

  • Bonneville Power Administration  
  • Consumer Financial Protection Bureau  
  • Department of Agriculture  
  • Department of Commerce  
  • Department of Health and Human Services  
  • Department of Housing and Urban Development (including the Office of Inspector General)  
  • Department of Justice  
  • Department of Labor  
  • Department of Veterans Affairs  
  • Environmental Protection Agency  
  • Federal Housing Finance Agency  
  • General Services Administration  
  • United States Agency for International Development 

GAO found that, while GSA established initial metrics for measuring program implementation, there was not a comprehensive plan with goals or a clear time frame for assessing the progress of the program. GAO found that GSA is collecting data on the purchases, but does not have a comprehensive plan with established targets or goals for how GSA will determine what percentage of sales is appropriate or what is an appropriate time frame to achieve these sales goals. GAO emphasized that more clarity on these objectives is critical, so that GSA can assess whether the program is operating successfully and whether any adjustments need to be made before launching the program governmentwide, as is the current plan. 

GSA has also developed a plan to monitor the platform provider’s compliance with the requirements to protect supplier and Government data. GAO found that GSA’s plan did not address all the areas of compliance and that it did not effectively prevent unauthorized activity. For example, GSA’s current approach to monitoring data protection does not monitor if providers are using the collected data for pricing, marketing, or other activities, which is prohibited under the data protection requirements. GAO stated that GSA will be able to better monitor compliance if they regularly review the providers’ policies.  

Based on GAO’s findings, they recommended that GSA create a comprehensive plan with goals and time frames for measuring program implementation and further develop its monitoring plan with specific actions to make sure that providers comply with their data protection requirements.  

 

$768 Billion Defense Bill Passed by House

On September 24, Federal Computer Week reported that the House passed the $768 billion National Defense Authorization Act (NDAA) for FY2022. The bill includes significant policy changes, such as expanding the military draft to include all Americans, improvements to software acquisition, and cyber education for DoD personnel. The bill also includes an amendment that seeks special immigration status for science and technology workers who are seen as essential to national security innovation. Another amendment would create four technology security centers through competitive grants from DHS to universities, Federally funded research and development centers, or national laboratories. The centers would conduct research focused on network technology, network industrial control systems, open source software, and Federal critical software. The Senate has not yet approved its version of the bill. 

 

Nina Ferraro Appointed as DHS Deputy Chief Procurement Officer 

Nina Ferraro will serve permanently as the Department of Homeland Security’s (DHS) Deputy Chief Procurement Officer. Ferraro previously served as the Senior Advisor to the Chief Procurement Officer. Her other roles within the agency included Acting Deputy Chief Procurement Officer and Executive Director of Strategic Programs in the Office of the Chief Procurement Officer. Prior to joining DHS, Ferraro worked as a Senior Procurement Executive at the Office of Personnel Management and was the Director of the Federal Protective Service Acquisitions Division. 

 

Zero Trust the New Standard  

Federal News Network reported that Federal cyber leaders say that zero trust looks like the “new normal” on the IT side of Government. The President’s May Executive Order 14028Improving the Nation’s Cybersecurity, was the catalyst for three documents to help agencies adopt Zero Trust cybersecurity principles. OMB released a draft Federal Zero Trust Strategy, to adapt civilian agencies’ enterprise security architecture to Zero Trust principles. According to Eric Mill, who is the senior advisor to the administrator of the Office of the Federal Chief Information Officer, if he had to pick a central theme and umbrella effort for the different security initiatives at the Office of Management and Budget, Zero Trust would be it. According to Mill, the “Biden Administration is leaning into stronger multi-factor authentication — especially to tackle phishing — and is pushing for stronger encryption.” He also said, “the Administration is emphasizing a heavier focus on validating security and practice on application testing, as well as putting security at the application level wherever possible.”   

The Federal Zero Trust Strategy also aligns with the Zero Trust Maturity Model, which the Cybersecurity and Infrastructure Security Agency (CISA) developed around data, applications, networks, and identity. This model is open for public comment through this Friday, Oct. 1. 

 

New NIST Cybersecurity Practice Guide Coming in 2022

Fedscoop reported that The National Institute of Standards and Technology (NIST) plans to publish various volumes of its forthcoming Cybersecurity Practice Guide throughout 2022 and beyond. By providing a description of the practical steps needed to implement the cyber reference designs for Zero-Trust security, the guide will be the end result of NIST’s Implementing a Zero Trust Architecture Project. Ideally, the Cybersecurity Practice Guide will not only be a best practices document, but a policy engine for agencies to enforce Zero Trust, said Tony D’Angelo, Vice President of Public Sector at Lookout, a San Francisco-based mobile threat defense company. “It will focus on different types of solutions but, overall, a general architecture and a blueprint for different agencies to follow,” he said.

 

It’s a Mandate: Task Force Issues COVID-19 Vaccine Guidance for Government Contractors

As required by President Joe Biden’s Executive Order on Ensuring Adequate COVID Safety Protocols for Federal Contractors on Sept. 9, 2021, the Safer Federal Workforce Task Force (the Task Force) issued its COVID-19 Workplace Safety: Guidance for Federal Contractors and Subcontractors (the Safety Guidance).

As expected, the main thrust of the Safety Guidance is a broad-based vaccine mandate for federal contractor workers. (See Holland & Knight’s previous alert, “President Biden Mandates COVID-19 Safety Measures for Government Contractors,” Sept. 10, 2021.) The mandate applies to individuals working on and “in connection with” covered contracts. In many instances, the mandate also applies to individuals working at a federal contractor’s workplace, even if the individuals do not themselves work on or “in connection with” a federal contract.

The Federal Acquisition Regulatory Council (FARC) has been tasked with drafting a rule by Oct. 8, 2021, and agencies will be requested to utilize the rule as class deviations so the rule can expeditiously be placed into contracts when permitted by the rule.

Covered contractor employees will be required to be fully vaccinated by Dec. 8, 2021, or whenever performance on a covered contract starts, whichever is later. Covered contractors are required to review a copy of each employee’s vaccination records (digital versions are acceptable) to verify vaccination status, which is a departure from the prior guidance allowing employee attestation without verification. The Safety Guidance specifies that covered contractors may be required to provide accommodations for employees who cannot comply with the vaccine requirement due to a disability or other medical conditions, or due to sincerely held religious beliefs, when there is a legal entitlement to such an accommodation. Covered contractors are responsible for considering and dispositioning such accommodation requests, and the Safety Guidance offers no examples of potential reasonable accommodations.

Types of Contracts Impacted

The definition of “contract or contract-like instrument” is adopted from the U.S. Department of Labor’s (DOL) proposed rule, “Increasing the Minimum Wage for Federal Contractors,” issued on July 22, 2021, and includes “all contracts and any subcontracts of any tier thereunder, whether negotiated or advertised, including any procurement actions, lease agreements, cooperative agreements, provider agreements, intergovernmental service agreements, service agreements, licenses, permits, or any other type of agreement, regardless of nomenclature, type, or particular form, and whether entered into verbally or in writing.” Like the minimum wage proposed guidance, the Safety Guidance lists contracts covered by the McNamara–O’Hara Service Contract Act (SCA), Davis-Bacon Act, concessions contracts and contracts in connection with federal property or land as examples of covered contracts. However, the Safety Guidance makes clear that this list is not exhaustive.

While contracts below the simplified acquisition threshold (currently $250,000) and contracts and subcontracts for products are not specifically included in the Safety Guidance, the Task Force is “strongly encourag[ing]” agencies to place the clause in contracts for products. Given this direction, contractors selling products to the federal government should anticipate that agencies will elect to include the vaccine mandate clause in their contracts.

While it is not entirely clear which types of contracts will be impacted by the new vaccine requirements (aside from the four types specifically mentioned in the Safety Guidance), contractors should expect that agencies will take a broad-based view and include the requirement in all contracts except for ones specifically excluded by President Biden’s Executive Order.

Individuals Impacted

It is clear from the broad language in the Safety Guidance that the Task Force intends to mandate the vaccine for as many individuals as possible, including:

  • all covered contractor employees working on or in connection with a covered contract, regardless of where the employee works, whether the individual works at a contractor’s worksite or from any other locations, including the individual’s private residence
  • all covered contractor employees, including those who do not work on or in connection with a covered contract, who work at a contractor’s worksite where there are other employees who work on or in connection with a covered contract and who are 1) physically present at that worksite or 2) who may visit that worksite during the period of performance for a covered contract

Covered contractor employees who work “in connection with” covered contracts are defined broadly under the Safety Guidance to include employees who perform duties “necessary to the performance of the covered contract,” including employees typically deemed as overhead such as human resources, billing and legal review. This is a notable change from previous regulations, which provided that workers must spend at least 20 percent of their time supporting contracts to be covered by the “in connection with” definition.

It is difficult to imagine scenarios where a covered contractor would not have all of their employees impacted by the mandate unless they can successfully demonstrate that an employee neither works on nor in connection with a covered contract and works in a location where no covered contractor employees will ever be physically present in that same location.

Other Requirements

While the vaccine mandate is an obvious focus, the Safety Guidance also sets forth other safety requirements for covered contractor employees who work in a location controlled by the contractor at which any employees who work on or in connection with a covered contract are likely to be physically present. In addition to following all guidance issued by the Centers for Disease Control and Prevention (CDC), the Safety Guidance requires:

  • masking indoors of unvaccinated individuals, regardless of the level of community transmission
  • masking indoors of vaccinated individuals when there is high or substantial community transmission
  • physical distancing for unvaccinated individuals when practicable, regardless of the level of community transmission, and fully vaccinated individuals do not need to physically distance

The Safety Guidance contains explanations for various scenarios (indoor versus outdoor and vaccinated versus unvaccinated) and other requirements that contractors should consult when developing policies. The Safety Guidance also requires covered contractors to designate one or more company representatives to coordinate the covered contractor’s COVID-19 workplace safety efforts at covered worksites.

What Should Contractors Do?

Assuming a contractor has a covered contract, they should:

  • develop and implement clear employee policies regarding vaccination, masking and physical distancing
  • implement and/or refine administrative and operational protocols for:
    • verifying employee vaccination status
    • evaluating employee accommodation requests in compliance with applicable law, including the Americans with Disabilities Act (ADA) and Title VII, and identifying and implementing reasonable accommodations as appropriate
    • monitoring and enforcing masking and physical distancing requirements, as well as other COVID-19 safety protocols
  • designate an individual or team of individuals to coordinate implementation and monitor compliance for each worksite
  • review modifications to contracts carefully, including the exercise of option years or mass modifications on Federal Supply Schedule (FSS) contracts for the vaccine mandate clause
  • flow down any clauses to the supply chain, including lower-tier subcontractors, as required by the clause
  • track costs associated with implementation of the vaccine mandate and other requirements to requesting an equitable adjustment or reimbursement
  • monitor additional related federal, state and local legal developments, including the anticipated COVID-19 Prevention Emergency Temporary Standard that President Biden has directed the Occupational Safety and Health Administration (OSHA) to implement in the near term

Implementation Timing

The executive order and Safety Guidance set forth the implementation timing:

  • the Federal Acquisition Regulatory (FAR) Council will develop a clause by Oct. 8, 2021, and ask agencies to issue class deviations consistent with the clause
  • for contracts awarded between Oct. 15, 2021 and Nov. 14, 2021, agencies are encouraged to put the clause in contracts awarded and required to place it in solicitations
  • for contracts awarded after Nov. 14, 2021, the vaccine mandate is required to be placed in contracts
  • covered contractor employees working on or in connection with a covered contract must be fully vaccinated by Dec. 8, 2021, or the first day of performance of a covered contract

Holland & Knight’s Government Contracts Group will review any publicly available information from the FAR Council and class deviations issued by agencies and issue a follow-up alert if warranted. For more information or questions regarding the Safety Guidance, please contact the authors.

 

 

OIG Issues Report on DoD Pharmaceutical Supply Chain Risk

On September 20, the Department of Defense (DoD) Office of Inspector General (OIG) published a report on the Evaluation of the Department of Defense’s Mitigation of Foreign Suppliers in the Pharmaceutical Supply Chain. The objective of the report was to determine if DoD has reduced risks of disruption to the pharmaceutical supply chain which relies heavily on foreign suppliers. In 2019, the Food and Drug Administration (FDA) determined that approximately 72 percent of active pharmaceutical ingredient (API) manufacturers supplying the U.S. market were foreign and 13 percent of those were in China. DoD is reliant on the commercial market for pharmaceuticals for its Service members. DoD is required to identify, monitor, and assess the security and potential disruptions within and outside of the DoD supply chain to reduce risk to supply chain operations.  

OIG found that the Defense Logistics Agency (DLA) identified DoD’s reliance on foreign suppliers in the pharmaceutical supply chain as a risk, but did not conduct a formal assessment of the risk in order to develop a mitigation strategy. OIG also found that for routine Military Treatment Facility (MTF) operations, the Defense Health Agency (DHA) and the Armed Services did not proactively assess risks of unexpected supply chain disruptions as instructed. Risks included DoD’s reliance on the commercial pharmaceutical market, which relies heavily on foreign sources. OIG found that DHA and the Services used “just-in-time” ordering for pharmaceuticals and did not store extra finished drug products that could be used in the event of a supply chain disruption. A supply chain disruption could compromise the standard of care to DoD beneficiaries as a result. Additionally, a disruption of the supply of foreign APIs to domestic manufacturers could cause a drug shortage, ultimately affecting the U.S. health care system and compromising the standard of care for service members and DoD beneficiaries.  

OIG recommends that the Under Secretary of Defense for Acquisition and Sustainment develop implementation guidance for DoD supply chain risk management for DoD materials, including pharmaceuticals. The Under Secretary of Defense for Acquisition and Sustainment should also seek Federal legislation that requires pharmaceutical manufacturers to include APIs and final drug product country of origin information on the pharmaceutical’s packaging. OIG also recommends that the Director of DHA develop and publish implementing guidance for supply chain risk management specifically for pharmaceuticals. Additionally, DHA should set up a working group to assess supply chain risks, identify the most critical pharmaceuticals for DoD beneficiaries, and establish a policy for allocating scarce pharmaceutical resources in the event of a supply disruption.

The VA Releases its September FSS eNewsletter

The Department of Veterans Affairs (VA) Federal Supply Schedule (FSS) program has released its newsletter for the month of September.  Topics covered are:

  • What’s New with FSS
  • Important Dates and Training for the 2022 Public Law Season
  • The VA FSS Director on the Value of the FSS Program
  • FSS FAQ
  • Applicability of the Trade Agreements Act
  • Upcoming Training & Events and more

To access the full newsletter, click here.

 

All Member Training on GSA e-Systems, Oct. 7

The Coalition will host a training open to all members on GSA’s e-Systems 101 on Thursday, October 7 at 10 am EDT.  The training will be conducted by Tim Dempsey, Lead Program Manager of the Operations Division in GSA’s Office of Systems Management (OSM) and Josh Royko, Director of GSA’s Acquisition Oversight Division.  

Our guest speakers will provide an extensive overview and update on the following GSA e-systems:  

GSA Advantage!  

  • eBuy  
  • eLibrary  
  • Mass Mod System  
  • Vendor Product Portal  

The training will also include discussion on the upcoming Unique Entity Identifier (UEI) that will replace the use of DUNS, FAS ID, Multi-Factor Authentication (MFA) and Schedule Refresh 7. To attend the virtual meeting, RSVP to Michael Hanafin at mhanafin@thecgp.org.   

 

Small Business Committee Meeting, Oct. 8

On October 8 at 10 am EDT, the Small Business Committee will host a meeting to discuss barriers to entry for small business when working with the DoD. We are discussing these barriers to prepare for the Coalition’s response to DoD’s request for comments released on September 8. According to DoD’s request, the participation of dynamic, resilient, and innovative small businesses in the defense industrial base is critical to the United States’ efforts to maintain its technological superiority, military readiness, and warfighting advantage.  In furtherance of its efforts to maximize opportunities for small businesses to contribute to national security, the Department seeks public input on the barriers that small businesses face in working with the Department. This input will be used to update the Department’s Small Business Strategy led by the DoD Office of Small Business Programs. In addition, DoD is focusing on complying with recent Executive Orders (EO), like EO 14017 “America’s Supply Chains,” to reduce entry barriers of small businesses.    

If you would like to attend the virtual meeting, please RSVP to Michael Hanafin at mhanafin@thecgp.org.  

The Coalition will submit comments through the Small Business Committee. If you are unable to attend the meeting, please send any input to Samantha Holt at sholt@thecgp.org by COB October 8. Comments are due by October 25.   

If you would like to attend the virtual meeting, please RSVP to Michael Hanafin at Mhanafin@thecgp.org.

 

BRIC/Cyber Committee Meeting, Oct. 12

The Coalition will be hosting a joint BRIC and Cyber Committee meeting on Tuesday, October 12 at noon. During this meeting, members will learn about federal contractor telework policy, including cyber requirements, labor rates, workplace environment changes and more. The speakers for the meeting are Townsend Bourne, Jonathan Aronie, and Ryan Roberts from Sheppard Mullin.   

If you would like to attend the virtual meeting, please RSVP to Michael Hanafin at mhanafin@thecgp.org.  

 

Joint IT/Services and GWAC/MAC Committee Meeting, Oct. 14

 

The Coalition is pleased to announce that the IT/Services and GWAC/MAC committees will be holding a virtual joint meeting with guest speaker Jeff Koses, Senior Procurement Executive for the General Services Administration (GSA) on October 14 at 1 pm EDT. Jeff will provide an update on GSA’s recent efforts/actions in support of the Biden Administration’s policy priorities. The session will include time for Q&A.  

If you would like to attend the virtual meeting, please  RSVP to Michael Hanafin at Mhanafin@thecgp.org.    

 

Buy American Act NPRM Deadline Extended to Oct. 28

The FAR Council has extended the comment period on the amendments to the Buy American Act from September 28, 2021 to October 28, 2021 to give additional time for interested parties to develop comments on the proposed rule and provide feedback on the questions posed in the preamble. On July 28, the FAR Council published a Notice of Proposed Rulemaking that would make changes to the implementation of the Buy American Act. The proposed rule addresses section eight of Executive Order (EO) 140005, Ensuring the Future is Made in All of America by All of America’s Workers signed by President Biden in January 2021. Specifically, the proposed rule calls for an increase to the domestic content threshold, a framework for application of an enhanced price preference for a domestic product that is considered a critical product or made up of critical components, and a post-award domestic content reporting requirement for contractors.  

The Coalition is submitting comments in response to the Notice of Proposed Rulemaking by October 28. The Coalition’s draft comments can be read here. Please submit any feedback on the draft comments to Tsisti@thecgp.org by COB Wed., October 20.  

Save the Dates for the 2021 Fall Training Conference—Nov. 17-18

Please take a moment to mark your calendar for the Coalition’s two-day virtual Fall Training Conference: “What’s Next for the Business of Government,” taking place on November 17-18.  We will be utilizing the same technology as our previous two conferences and are looking forward to your participation.  Stay tuned for further updates as we anticipate releasing our draft agenda next week!  For sponsorship inquiries, please contact Matt Cahill at mcahill@thecgp.org or 202-315-1054.

DoD Request for Input on Implementation of COVID-19 Contractor Requirements  

On September 17, DoD announced an early engagement opportunity for the public to provide early comments on the department’s implementation planning for the Executive Order 14042 (EO), “Ensuring Adequate Safety Protocols for Federal Contractors.” Comments should be submitted through the Defense Acquisition Regulations System (DARS) website at https://www.acq.osd.mil/ dpap/ dars/ early_ engagement.html or via email to osd.dfars@mail.mil with the reference “Early Engagement Opportunity: E.O. 14042” in the subject line. Comments are due by October 17, 2021.  However, DoD has indicated that comments submitted earlier will be most valuable to the development of their implementation plans.