Author Archives: Nicole Pottroff

GSA Demystifies DUNS Replacement ID

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“Change can be confusing. Change can be frustrating.” No, this is not from the cover of a self-help book. This is GSA’s acknowledgment that, often, we fear change.

To combat fears about changes to the DUNS number, GSA recently released a Q&A providing some answers on the new Unique Entity ID (UEI) Standard, which is set to replace the current DUNS system in December 2020. The Q&A followed GSA’s online meeting on the topic in July, which hosted over 700 attendees. GSA answered general questions about the transition, the UEI that will be used, and how to obtain a new identifier. Let’s take a look.

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GSA On Track to Release Consolidated MAS Program Schedule On First of October

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This week, GSA announced it is on track to debut its Consolidated Multiple Acquisition Schedule (MAS) Program Schedule Solicitation on October 1. GSA also gave federal contractors planning to bid on the MAS a head start on the process by releasing a final draft solicitation and an updated industry FAQs sheet.

Let’s take a look at how to utilize this opportunity to prepare for the solicitation’s long-awaited debut.

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GAO to Agency: Offerors are More than Just a CPARS-Generated Rating Percentage

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GAO recently sustained protest to an agency’s FAR Part 13 procurement that relied exclusively on CPARS-generated assessment chart rating percentages to evaluate vendors’ past performance. The agency’s goal was to “maximize competition” by considering all past work, rather than just relevant work.

While there is no FAR Part 13 regulatory prohibition on doing so, GAO found the CPARS charts incomplete and misleading and the evaluation inconsistent with the terms of the solicitation.

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GAO: Proposal Strengths Must be Based on Solicitation Criteria, Not Merely Benefit to Government

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Agencies often find unanticipated, innovative content in offerors’ proposals. And unsurprisingly, those proposals are often the ones selected for award. But a recent GAO decision reminds us that all strengths an agency assigns must be supported by the stated evaluation criteria.

In other words, the solicitation must thoroughly inform offerors of these evaluation criteria, and the agency must equally evaluate offerors under them. An offeror’s proposal should not get extra credit for proposing things that are not anticipated by or logically encompassed in the solicitation.

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U.S. Government to Ditch the DUNS

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Earlier this month, the GSA announced a new Unique Entity Identifier Standard for Federal awards management. The new standard will go into effect December 2020. It will replace the current DUNS number system as the official identifier for all businesses contracting with the U.S. Federal Government.

This should make registering to do business with the federal government a little easier, but the proof will be in the roll-out.

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2020 NDAA: Contractors Supplying Technical Data to Receive Protection of Data Rights During Challenges, Again

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The draft 2020 National Defense Authorization Act, if enacted, will revoke the government’s ability to exercise rights in technical data during a supplier’s challenge to the contracting officer’s decision as to the validity of the asserted “use or release restrictions” on that data. It would reinstate the previous safeguard afforded to data suppliers, allowing them to protect their valuable–and often irreplaceable–intellectual property rights unless and until the contracting officer’s decision to remove the restrictions is sustained.

Keep in mind, this is just a draft provision, as the Senate version of the 2020 NDAA doesn’t contain the provision discussed in this blog.

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GSA Announces Plans to Consolidate MAS Contracts and Asks for Industry Feedback

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The General Services Administration is conducting market research for its planned consolidation of the Multiple Award Schedule (MAS) Program. Earlier this month, GSA publicly announced the new single solicitation format, including streamlined terms and conditions, and its intention to collect feedback from government contractors in the industry.

According to GSA, the consolidation is part of its two-year modernization process for the program that began in November of 2018. The consolidated MAS solicitation is scheduled for release later this year. And if you have concerns or suggestions for GSA on this significant consolidation, there is still time for your input.

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