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Effective Oct. 26, you must be registered in SAM before you submit a federal bid, proposal or quote

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It’s official: If you intend to pursue a federal contract, your business must be registered in the System for Award Management (SAM) before you submit a bid, proposal, or quotation. The new rule that makes this clear goes into effect on October 26, 2018.

Any wiggle room that may have existed in the past has been eliminated. SAM registration is now imperative if you are interested in federal contracting.

It used to be that SAM registration was required before a contract could be awarded. The Federal Acquisition Regulation (FAR) at Subpart 4.1102(a) made that clear. But that requirement was always a bit ambiguous since another provision of the FAR (Subpart 52.204-8(d)) said that bidders and proponents had to complete the representations and certifications in SAM as a condition of making their offer. As a matter of practical interpretation, most federal contracting officers simply made sure that an offeror’s SAM registration was complete before awarding the offeror a contract.

That latitude goes away on October 26, 2018. On that date, FAR Subpart 4.1102 is officially amended to require all entities (i.e., vendors, including joint ventures) to be registered in SAM at the time they submit an offer (a bid or proposal) or submit a quotation to a federal agency. In essence, vendors who are not registered in SAM are ineligible to submit offers or quotes – effective October 26, 2018.

Keep in mind that the SAM registration process can take time to complete. If you’re planning to compete for a federal contract in the future, you should complete your SAM registration as far in advance as possible. And, if you are already registered in SAM, remember that your SAM registration must be renewed at least annually – and renewed whenever any part of your registration needs to be updated.

If you need help with your company’s SAM registration, feel free to request counseling with the Virginia Procurement Technical Assistance Program (Virginia PTAP). If you are an existing client and aren’t sure which counselor to reach out to, contact your local office for scheduling: https://virginiaptap.org/contact/.

If you are located outside of the state of Virginia, you can find the procurement technical assistance center (PTAC) nearest you at: http://www.aptac-us.org/contracting-assistance

Remember: There is never a fee to register in SAM as a government contractor. PTACs are available with no-cost help to get you through the process.

SAM is located at: https://sam.gov. But before beginning the SAM registration process, you must first take care of the following:

  1. Obtain a DUNS Number by registering your Legal Business Name and Physical Address with Dun & Bradstreet (D&B). If you don’t already have a DUNS Number, you can request a DUNS Number for FREE from D&B at: http://fedgov.dnb.com/webform
  2. Make sure you have a Taxpayer Identification Number (TIN) associated with the Legal Business Name registered with D&B. To obtain information from the IRS on how to obtain a TIN, visit: https://www.irs.gov/individuals/international-taxpayers/taxpayer-identification-numbers-tin
  3. Have your bank’s routing number handy, including your bank account number and your bank account type (i.e., checking or savings). You’ll need this information to set up Electronic Funds Transfer (EFT) in SAM. The federal government makes virtually all contract payments via EFT.
  4. The first time you log in to SAM.gov, you’ll be asked to create a login.gov user account (if you don’t already have one). Going forward, you will use your login.gov username and password every time you log in to SAM.gov. Existing SAM.gov usernames and passwords no longer work.

Article adapted courtesy of the Georgia Tech Procurement Assistance Center

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Department of Defense’s SBIR/STTR online training calendar – free 2018 webinars

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The Department of Defense’s SBIR/STTR Program Office has put together an on-line training program catalogue for small businesses for the year. Upcoming SBIR/STTR webinar topics are listed below, along with dates. More information on each title is found on the registration site. All are offered free of charge.
  • How to Use the DOD SBIR/STTR Submission Site / Important Proposal Considerations / Using SITIS – May 24, 2018
  • Managing Intellectual Property – Important Business Considerations for Commercialization – June 5, 2018
  • Understanding the Evaluation Process/What to Do with a Debrief – June 26, 2018
  • Working with Prime Contractors – July 17, 2018
  • The DOD Acquisition Process / Contracting – August 1, 2018
  • Commercialization Assistance Programs and Beyond Phase II Considerations – Sept. 4, 2018
  • Manufacturing / Working with MIBP – September 18, 2018
  • Testing and Evaluation – October 9, 2018
  • Phase III Process – How to Identify Non-SBIR – October 30, 2018

Posted in: Uncategorized, Upcoming Events

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CVE Special Alert – VIP Enhancement and 30-Day Suspension Notice

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Adapted from the announcement sent by CVE to PTAC counselors and of special interest to any CVE applicants or renewals now through late June 2018: VIP Enhancement and 30-Day Suspension Notice

1. On May 14, 2018, the U.S. Department of Veterans Affairs (VA), Office of Small and Disadvantaged Business Utilization (OSDBU), Center for Verification and Evaluation (CVE) began the rollout of the new Vendor Information Pages (VIP) to support the Vets First Verification Program. OSDBU and CVE are committed to improving customer service and the overall Verification experience. The enhanced VIP will enable OSDBU to manage all aspects of the Vets First Verification Program more effectively, and improve the online experience of Veterans.

2. On May 21, 2018, CVE will suspend incoming case applications to facilitate the transition to the new case VIP interface. The suspension of incoming cases will last for approximately thirty (30) days and include both new applications and reverifications. CVE will continue processing previously submitted applications during the suspension period. As such, any applicants (Veteran businesses) that desire to have their applications begin the verification process before the suspension start date, should strongly consider submitting their applications to VIP prior to May 21, 2018.

3. Major VIP enhancements include:

  • Single Sign-On login process – You must have a DS Logon (Veterans) or create an ID.me Account (Non-Veterans and Representatives) to access the re-designed VIP
    o Enrollment in the Defense Enrollment Eligibility Reporting System (DEERS) is required to obtain a DS Logon
    o DS Logon and ID.me account access instructions are attached DS Logon and ID.me Account Instructions
  • System for Award Management (SAM) registration and Data Universal Numbering System (DUNS) validation:
    o Automatic when the user inputs the DUNS
    o Elimination of Veteran frustration when submitting applications with incorrect DUNS or incomplete SAM registration
  • New user specific dashboard capabilities and Veteran process enhancements:
    o Easier to upload individual and business tax returns
    o Ability to upload or create resume
    o Easier to sign VA Form 0877
    o Ability to designate a representative to serve as proxy for only specific designated owners
    o Ability to track all verification application information in one unified location/view
    o Ability to submit and track the status of Help Tickets
    o New calendar capability to view appointments with Case Analysts
    o Ability to automatically request/receive ten-day extensions for most document requests (not including risk, status protest or cancellation related requests)
    o Application audit submission feature identifying outstanding tasks requiring completion prior to submission

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Recent development in the DOD cybersecurity regulations

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An update to our December post on implementation of a NIST SP 800-171r: This past Tuesday (April 24th 2018), DOD issued draft regulations on its cybersecurity clause DFARS 252.204-7012.  Attached are pdf copies of the Federal Register notice plus the two documents referenced in the notice.

PTAP has been advised that DOD has implicitly acknowledged that contractor implementation of a NIST SP 800-171r cybersecurity plan is not going as anticipated.  The draft guidance explains three levels of priority within an implemented System Security Plan (“SSP”). The utility of the priority levels is that DOD has identified the priorities on an item-by-item basis per the NIST security requirement.  For example, multifactor authentication (NIST 171, 3.5.3) is a priority 1 (“P1”) while monitoring security controls (NISAT 171, 3.12.3) on an ongoing basis is a priority 3 (“P3”).  DOD is again focusing on the development of SSP as supplemented by a Plan of Action that includes an implementation schedule.

More importantly, and as highlighted during the presentations sponsored by PTAP, DOD has emphasized that SSPs (with or without an accompanying Plan of Action) will be an evaluation factor used to discriminate among offers as a means to evaluate the government’s overall risk of providing “covered Defense information” to contractors who then use or store CDI on their IT systems.  Specifically, the draft guidance states that RFP’s must require delivery of NIST SP 800-171 Security Requirement 3.12.4 – System Security Plan (or specified elements of) and [NIST-171] Security Requirement 3.12.2 – Plans of Action with the contractor’s technical proposal.

Thanks to David B. Dempsey of Dempsey Fontana, PLC of making us aware of these recent developments!

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Your Elevator Pitch Needs Work

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… or you wouldn’t be reading this.

Yes, you. The “small, woman-owned company established in 2008, located in Alexandria, VA, that prides itself on excellent customer service and always striving to do best for our clients“.  Because if that sounds like you, you just wasted 20 seconds of everybody’s time for no good reason.

A truly great elevator pitch takes planning, practice, and precision. Especially in government contracting, where industry events are comprised of many companies of similar industries, you need to stand out, or you may as well be invisible.  Here’s what I mean:

  1. Planning. Know your audience.  Who is going to be in the room? What is the key takeaway you want them to remember? How will your 30-second opportunity set you apart from everyone else?  The point of the elevator pitch is for the listeners to spark an interest. Not to pre-emptively answer all their questions.  Naturally, your elevator pitch will be different in an open forum, in a 1-on-1 with a government agency, a potential teaming partner, or a banker.
  2. Practice. Every time you say “umm” or “you know” or “as I said” – you’re stealing seconds from your allotted time; losing the listeners’ attention; and killing your credibility as an expert.  Know what you will say ahead of time. Run it by a few people – a family member, friend, partner, a PTAP or SBDC counselor.  Be sure to test on people that don’t know the technical specifics of what you do, because if you’re speaking in code (or jargon), your customers may not understand what you’re saying.
  3. Precision. What are the key elements you want to convey that would want your listener to want to ask you more questions?  Look at a few templates for constructing the pitch, You can start  with this guide or this one. A generic, 1-size fits all blurb will fit no one. An appeal targeted specifically for the present audience will be more productive.

 

 

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Civilian Agency Micro Purchase Threshold Increased to $10,000

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The FY2018 NDAA increases Micro Purchase threshold to $10,000 (from $3,000).  Total Simplified Acquisitions Purchase (SAP) threshold is now $250,000 (from $150,000)

This can be a gamechanger for small businesses trying to get a “foot in the door” with federal agencies; the government customers now have a mechanism to pave the way for a streamlined, simplified way to award contracts.  Micropurchases are small business set-asides by default.

Read the Civilian Agency Acquisition Council memorandum to agencies – Appendix 2 outlines which FAR clauses are affected by the change.

A great summary and explanation by Matthew Moriarty at SmallGovCon Law

Note: the FAR has not been updated yet, so agencies have to use a “class deviation” to avail themselves of the newly adjusted ceilings.

Currently, here’s the summary according to the SBA

 

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Are your NIGP Codes valid? (Commonwealth of Virginia Vendors)

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Virginia Department of Small Business and Supplier Diversity (SBSD) reviewed the list of certified and pending Small, Women, and/or Minority (SWAM)  companies. They issued a letter to businesses who had an invalid NIGP code (one ending with 000) – the number ending in ‘triple zero’ is a category and not an actual code.  Any invalid code(s)/description(s) will be deleted from your profile by February 23rd.

To locate proper NIGP Codes for your company, click here.

EXISTING SWAM Certified Companies: The letter includes instructions on updating your NIGP Codes.

APPLICATIONS PENDING Companies:  Do NOT to change the NIGP codes in the electronic application at this point.  Doing so will reset the submitted date of their application and result in the  60-business-day waiting period to be reset.  To correct the codes, fill out the SWAM notice of change form and send to SBSD, and the agency will update the codes.

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Dept. of Navy Rapid Innovation Fund (RIF) program update

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January 2018 update on the Dept. of Navy Rapid Innovation Fund (RIF) program:  Good news especially for small, innovative companies who want to perform final development and testing and sell the resulting product to the DOD:  Section 213 of the FY17 NDAA removed the RIF program sunset clause, providing permanent authority for the program.  While the FY18 defense appropriation is still pending, and a RIF plus up is necessary, OSD is gearing up for an FY18 RIF BAA in the Feb/March 2018 timeframe, which will include topics from all the defense services.  Typical service-wide RIF funding available is $200-250M.  The full BAA schedule and latest info is at http://www.defenseinnovationmarketplace.mil/rif.html.

 

Government TPOCs can talk openly now; communications become restricted upon BAA release.  Historically, about 2/3 of Dept. of Navy RIF awards go to fund projects which derive from the SBIR program.  It’s easy to apply for RIF (three page white paper + quad chart), but the competition is quite fierce (~4% of white papers result in a full proposal invite).  Interested companies may want to review the FY17 BAA-Amendment 2 (Dept. of Navy topics on pages 45-69) now as many of the topics represent persistent Dept. of Navy needs.  This National Defense Magazine article provides sound advice.

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Brenda Pickett
Director, Office of Small Business Programs
Office of Naval Research
875 North Randolph St.
ONR Code: 00SB
Attention: Brenda Pickett
Arlington, VA 22203-1995
Tele: 703-696-2607
Email: brenda.pickett@navy.mil

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Should You Bother with a Capabilities Statement?

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Spend enough time at matchmaking events, industry days, networking events and conferences in the #GovCon world, and one could amass quite a collection of Capabilities Statements.  If one were into collecting them.  Which I am:

The capabilities (or capability) statement is your business’s resume; as such, it needs to combine the technical skillset you’re offering with an attractive format that would cause a neutral third party to pick it up and glance at it.  There are plenty of resources (APTAC, HHS, SAP&DC) who will tell you what to put in it.  ISI Federal lays it out in a graphical format. FDIC has a whole slide deck.  I’d like to take you through a slightly different analysis:

“Who [or what] is it for?”

  1. Fitting in. I have seen more than one Small Business professional, representing government and prime contractors, ask for a capabilities statement right at the start of a conversation at a matchmaking event.  If you don’t have that, it looks like the dog ate your homework.  Not the first impression you were going for
  2. Benefits and Features. A quick glance at a well-constructed capabilities statement will give your reader an understanding of how your services or products will help them solve a problem in their organization. As such, it should highlight the results of your work, defining what you do with enough specificity to enable an informed buyer to be impressed.  If you can’t think of any way to impress or stand out, you probably shouldn’t be competing in the first place.
  3. Category box-checker. All the socio-economic and small business statuses and certification need to be there for easy reference. As well as your location, contact info, vendor (SAM / CAGE) numbers, NAICS codes, and any contract numbers that your customer may care about.  Sometimes capabilities statements are a component of market research – help your customers make the case of a set-aside (without repeatedly bashing them over the head with your status).
  4. Conversation re-starter. It’s on you to follow up to any great meeting to grow a relationship and turn a spark of interest into a true business lead. As such, a solid capabilities statement could be a good follow-up email attachment, for reference & recollection.  An electronic document, properly labeled and formatted, also makes it easier for your customer to store it and refer to it as necessary.

Is your one-pager ready for prime time?  Make sure you’re not guilty of any egregious “Don’ts“. Keep your customer paramount in your mind when you’re writing and designing: will she want to pick it up? Read it? share it?  Do you even know who your customer is? If not, do your homework first.

And if you would like some help, contact your local PTAP / PTAC. We’ve got our red pens at the ready.

 

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