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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.

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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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NIST and DFARS and Cyber Compliance! (oh my)

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You have doubtless heard and read all about the looming requirement for all Department of Defense government contractors to become compliant with Defense Federal Acquisition Regulation Supplement (DFARS) minimum security standards derived from NIST SP 800-171 Rev 1 by Dec 31, 2017- or else risk losing their contracts.  DFARS Clause 252.204-7012, Safeguarding Covered Defense Information and Cyber Incident Reporting, will be a mandatory clause in all contracts except for contracts solely for the acquisition of COTS items.

This requirement applies to any DoD Contractor, subcontractor, and supplier ALL THE WAY DOWN THE SUPPLY CHAIN that processes, stores, or transmits Controlled Unclassified Information (CUI). Not just security contractors. Not just companies that have clearances. Not even just IT contractors.  If you have a landscaping business and you are performing work at a DOD facility, and have access to blueprints that are or may be considered CUI, you’re subject to this requirement.  CUI includes the categories outlined in the NARA CUI Registry, but as you can probably imagine, is not limited to that. your government customer can identify additional categories and data, and you as a contractor, should err on the safe side and identify potential CUI so that you can protect and segregate it just in case.

Note: civilian contractors are not subject to this requirement (there are only 15 security controls outlined in FAR part 52.204-21 compared to 109 in the DFARS clause), but that may be changing to synthesize the compliance requirements to the more complete set that the DOD/DFARS adopted.

Ultimately, it is the contractor’s responsibility to determine whether it is has implemented the NIST SP 800-171 (as well as any other security measures necessary to provide adequate security for covered defense information).   Third party assessments or certifications of compliance are not required, authorized, or recognized by DoD, nor will DoD certify that a contractor is compliant with the NIST SP 800-171 security requirements.

The protections required to protect government information are dependent on the information DoD is protecting and the kind of system on which the information is processed or stored.

There is no single or prescribed manner in which a contractor may choose to implement the requirements of NIST SP 800-171, or to assess their own compliance with those requirements.  For companies new to the requirements, a reasonable first step may be for company personnel with knowledge of their information systems security practices to read through the publication, examining each requirement to determine if it may require a change to company policy or processes, a configuration change for existing company information technology (IT), or if it requires an additional software or hardware solution.

Some resources and tools to help you determine whether you’re subject to the requirement, and what you can do next:

  1. DOD Office of Small Business Cyber resources and news – especially the 49-minute video and the presentation slides
  2. DOD Procurement Toolbox – Cyber security section (including how to approach evaluating each requirement)
  3. Georgia Tech PTAC 20-min Instructional Video
  4. A handy presentation [from a law firm] that translates the major requirements into easy-to-understand terms
  5. The Safeguarding Covered Defense Information one-pager to ease you into the basics.
  6. The Cybersecurity Evaluation Tool (CSET) that provides a systematic approach for evaluating an organization’s security posture through a step-by-step process to evaluate their control system and information technology network security practices.  The tool will allow you to select a standard (e.g. NIST SP 800-171) – and CSET will generate specific questions to those requirements and present you with assessment results.
  7. A  Self-assessment guide when you’re ready for the deep dive
  8. OSD Memorandum: DPAP Guidance for DoD Acquisition Personnel that instructs DOD buyers how to implement and evaluate vendor cyber compliance (and since it’s going to be an evaluation factor in source selection, you need to know what your customers expect).
  9. For subcontractor and supplier reference – Lockheed Martin’s notice to its supply chain that you may find informative and applicable regardless of who your prime is.
  10. And if you heard the rumors of possible delay and were wondering if they have merit — sadly, no.

PTAP counselors can help you walk through these steps. While we’re not technical experts on network security, we could help you walk through the self-assessment and determine what steps you need to take to bring your business up to compliance.

 

 

 

 

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Passing along a message from FEMA

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Greetings,

Thank you for the Federal Emergency Management Agency (FEMA) regarding your interest in doing business with FEMA.  If you are contacting FEMA seeking to do business in support of a disaster recovery effort, please be aware that in accordance with the Robert T. Stafford Act, FEMA’s goal is to seek local companies within the disaster area for services related to a specific disaster when practical and feasible.  The ILP establishes strategic relationships with suppliers and stakeholders; serves as an information provider for suppliers seeking to do business with FEMA; and connects suppliers with program offices in support of FEMA’s mission.  The ILP encourages your business to review the information referenced below.

  1. Register with the System for Award Management (SAM)

Official Federal Government registration is processed within SAM www.sam.gov .  Direct all questions regarding the SAM registration process to the Federal Service Desk at1-866-606-8220.

To get started with your SAM registration, you must have the following:

  1. Voluntary submission of the Vendor Profile Form

The Vendor Profile Form can serve as supplemental market research for the agency.  Information supplied should not be proprietary or sensitive in nature. Please be specific about how your products and/or services can support FEMA’s mission. Submission of the Vendor Profile Form does not imply a guaranteed meeting or contract award. 

*Please click on the following link to access the vendor profile form:Indusry Liaison Program Vendor Profile Form < Caution-https://www.fema.gov/media-library/assets/documents/29748 >  and submit the form toFEMA-Industry@fema.dhs.gov < Caution-mailto:FEMA-Industry@fema.dhs.gov > 

*NOTE: FEMA does not charge any company a basic registration fee.  There are companies that replicate services of Federal Government entities and there are typically fees associated with their services.  Most Federal Government services, if not all, are free of charge.  Always make it a practice to reach out to the appropriate Federal agency first to inquire about the validity of the service, specifically if a fee is associated with it.

All meeting requests are at the discretion and availability of the FEMA Contracting Officer, Program Office, and FEMA representatives.  If the agency identifies the need to meet to further discuss your company and its capabilities you will be contacted. 

Types of Meetings Currently Offered:
  • Face-to-Face Meetings
  • Conference Calls
  • Topical Educational Sessions (TES) – These sessions will be periodically offered virtually to provide mission specific information relative to various FEMA programs
  • Industry Days – Will be posted onFBO.gov < Caution-http://FBO.gov >  as applicable to program requirements
Learn More About:
  • Donation and Volunteering – Please visit FEMA’s Volunteer & Donate Responsibly page https://www.fema.gov/volunteer-donate-responsibly .
  • Debris Removal – Become a member of the Corps of Engineers Contractor Registry if you are interested in performing disaster response and recovery work; e.g. debris removal.  Follow this link to access their website// www.usace.army.mil/Missions.aspx
  • FEMA Industry Liaison Program –http://www.fema.gov/about-industry-liaison-program
  • FEMA – https://fema.gov
  • FEMA Small Business Program –All Small Business inquiries should be directed to FEMA-SB@fema.dhs.gov
  • Department of Homeland Security Vendor Outreach Session – www.dhsvoms.moriassociates.com
  • Contracting Opportunities –You are encouraged to visit the following websites to identify such opportunities:
  • Federal Business Opportunities –Free web-based portal which allows vendors to review Federal Procurement Opportunities www.fbo.gov
  • DHS Advance Acquisition Planning System: Monitor the forecast of DHS contract opportunities at DHS Advance Acquisition Planning System http://www.dhs.gov/xopnbiz/opportunities/gc_1300288340710.shtm  .

We trust that this information will prove helpful.  If we may be of further assistance, please contact us at the email address or phone number listed below.

Regards,

Industry Liaison Program
Business Relations Branch
Acquisition Program and Policy Division
Office of the Chief Procurement Officer
Email:    FEMA-Industry@fema.dhs.gov < Caution-mailto:FEMA-Industry@fema.dhs.gov >
Phone:    (202) 646-1895
Website: Caution-http://www.fema.gov/about-industry-liaison-program

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