April 3, 2013 by cs
Still struggling with moving your Central Contractor Registration (CCR) records to the new System for Award Management (SAM)?
Last year, SAM replaced CCR as the federal government’s vendor database, and it’s extremely important for every business that wants to do business with the government to be properly registered in SAM.
The SAM system has proven to be a formidable challenge for many vendors, but now there’s a video that walks you through the steps of migrating your records from CCR to SAM.
You can view the instructional video at http://www.youtube.com/user/GSASAMVideos.
If your business was never registered in CCR, your starting point is http://www.youtube.com/watch?v=9VPGVYPvch4&list=UUGYKiouhiBpijT51CplQZ-w.
August 24, 2012 by cs
In order to avoid delays in “the timely processing of awards,” the U.S. Department of Defense (DoD) has ordered the temporary suspension of rules requiring vendor registration in the System for Award Management (SAM).
SAM replaced Central Contractor Registration (CCR), the government’s long-standing vendor database. SAM was launched during the last weekend in July 2012 when CCR vendor data was migrated to the new system.
SAM’s late July implementation included not only CCR but Federal Agency Registration (FedReg), the Online Representation and Certification Application (ORCA), and the Excluded Parties List System (EPLS) as well. “Performance issues” involving the new SAM database prompted DoD’s action to suspend for “a brief period” the requirement that vendors be registered in SAM before being eligible for a contract award.
Keep reading this article on The Contracting Education Academy at Georgia Tech’s web site at http://contractingacademy.gatech.edu/2012/08/dod-temporarily-alters-vendor-registration-rule-due-to-sams-launch-shortcomings.
- For the latest news involving SAM, please visit: http://gtpac.org/tag/sam.
August 15, 2012 by cs
The General Services Administration has officially ordered IBM to fix the troubled System for Award Management (SAM).
Sources confirmed GSA issued IBM a letter of concern Aug. 7. In the official notice, GSA told the company to develop a plan of action and milestones for how they will make SAM work more smoothly. Under the program, GSA wants to consolidate eight acquisition databases, including the Central Contractor Registration, the Past Performance Information Retrieval System and six others.
A letter of concern is a step before a cure letter, saying there are problems with the system but it’s not as bad as a cure letter.
GSA hired IBM under an eight- year, $74.4 million contract in 2010.
Keep reading this article at http://www.federalnewsradio.com/65/2988217/GSA-issues-letter-of-concern-for-problems-with-procurement-system.
- For the latest news involving SAM, please visit: http://gtpac.org/tag/sam
August 1, 2012 by cs
If you want to successfully pursue a government contract, it is essential that you register your business in the federal government’s vendor database. In fact, you may have received an advertisement from someone who is offering to register your business – for a fee – in a vendor database.
Before you rush to register – and certainly before you pay someone to register for you – you should learn what the registration process is all about, and how you can do it yourself.
The federal government’s vendor database was known as CCR – Central Contractor Registration. But on July 30, 2012, CCR went away. It’s been replaced by SAM – the System for Award Management. If you were registered in CCR, your information has migrated over to SAM. This migration covers even firms whose CCR registration information hasn’t been kept up to date.
You can access SAM at https://www.sam.gov.
But before you start the SAM registration process (or modify your existing record), it is very important to “get ready” by thoroughly acquainting yourself with SAM’s purpose and the information you’re expected to know in order to register properly.
We don’t want you to learn the hard way that registering in SAM with incorrect or incomplete information is worse than not registering at all.
The Georgia Tech Procurement Assistance Center (GTPAC) provides advice to Georgia businesses every day on the subject of proper vendor registration. In the course of providing this assistance, our Procurement Counselors review many existing registrations and registrations in progress. Based on our reviews, GTPAC estimates that at least 20 percent of the 600,000 firms presently registered in SAM have errors in their records. The mistakes range from misspelled words to empty data fields, to incomplete entries, to selection of incorrect procurement codes, and other flaws. As a result, these vendors miss-out on government contract opportunities either because they are screened-out for not exhibiting attention-to-detail or – because of incomplete information – they cannot be identified by government buyers.
SAM is the federal government’s primary source for identifying potential vendors. Every federal agency, both civilian and military, utilizes the SAM database. Many federal contract officers initially determine whether a contract should be set-aside exclusively for 8(a), HUBZone, or service-disabled small businesses based on firms identifying themselves with these designations in SAM. Prime contractors also use SAM to identify potential subcontractors and suppliers, with emphasis on the various small business socio-economic categories like those just mentioned plus women-owned small businesses, veteran-owned businesses, and small disadvantaged businesses. Even state and local governments sometimes consult the federal database to find potential vendors who are interested in the broader governmental marketplace. In addition, businesses and non-profits must be registered in SAM in order to receive federal payments and disbursements against contracts and grants.
Are you beginning to see proper registration in SAM in a new light, including what an important tool SAM is to effectively market yourself to the government? Truly, SAM is much more than a mere task to quickly get out of the way!
In preparation for registration in SAM, there are several steps you should take.. Among these steps are:
- Obtain a TIN/EIN for your business from the IRS. (Even if your business is a sole proprietorship, it’s important — because of identity-theft considerations — that you do not operate your business using your Social Security number.)
- Obtain a DUNS number for your business. (Don’t pay anyone for this; a DUNS number can be obtained from Dunn & Bradstreet — D&B — at no cost via the web within a day or two.)
- Research and identify the PSC/FSC and NAICS codes most appropriate to your business. (Every product and service is classified by these federal numbering systems, and it’s essential that you identify the codes that are applicable to your business.)
- Determine whether your business meets the SBA’s small business size standard. (Virtually every federal contract valued at less than $100,000 is awarded to small businesses, so you need to know if you qualify.)
- Write a brief capabilities statement. (You must have a grammatically-correct, short description of what your company does.)
- Identify “key words” associated with the nature of your business. (These words should be crafted from a government buyer’s perspective; in other words, think about what the government might ”call” what it is you do or sell.)
- Make a list of business references. (Be prepared to provide company name, contact person, dollar value, and date range of work.)
These are not all of the preparatory steps, but they are the most important ones. Plan ahead! It can take up to five days for your SAM registration to take effect because the SAM database must synchronize with D&B and IRS databases before activating your registration.
If you have questions or need help with any aspect of SAM, please consider taking advantage of GTPAC’s services in a comprehensive way. GTPAC provides assistance to help Georgia firms get ready as well as find and pursue contracting opportunities in federal, state, and local government markets. This assistance is provided at no charge. Complete details on how to access GTPAC’s services can be found on our ABOUT US page.
And a great way to learn about how you can develop each of the 7 items listed above is by attending GTPAC’s “Introduction to Government Contracting” class or “Fundamentals of Working with the Government” briefing. Click here to see the dates and locations of these no-cost training opportunities.
One more thing: As this article is being written on Aug. 1st, SAM is just being rolled-out. There is a record number of vendors, coupled with a record number of contracting officers, who are visiting the SAM website to validate and update records. As a result, SAM is running slowly, and the on-line system is not always responding as it should. Be patient, is our advice. Try accessing SAM late at night or on the weekend when there are not so many users trying to access SAM data. Over time, the new SAM system will smooth out and offer more advantages than CCR ever did.
For the latest news involving SAM, please visit: http://gtpac.org/tag/sam
© 2012 Georgia Tech Procurement Assistance Center – All Rights Reserved.
July 24, 2012 by cs
Effective 11:59 pm on Tuesday, July 24, 2012, no new vendor registrations can be submitted to the federal government. Central Contractor Registration (CCR) is closing and will become part of SAM — System for Award Management — on Monday morning, July 30, 2012.
Thus, until the morning of July 30, 2012, vendors will not be able to initiate a new registration or modify an existing one.
Any registrations in process will be on hold until SAM goes live the morning of July 30, 2012. If a firm is in the middle of a registration, the data submitted will be migrated to SAM.
Similarly, all existing vendor registrations — both active and inactive — will be migrated to SAM.
When it is time to renew a registration, vendors should go to SAM.gov, create a SAM user account, and follow the online instructions to validate and update the information. Vendors only need to register for a user account in SAM when it is time to begin updating their current registration. Vendors do not need to do anything right away.
If a vendor’s CCR record was scheduled to expire between July 16, 2012 and October 15, 2012, the government is extending that expiration date by 90 days. Vendors will receive an e-mail notification from CCR when their expiration date is extended. Vendors will then receive standard e-mail reminders to update their records based on their new expiration date. Those future e-mail notifications will come from SAM.
CCR is just the first federal database to be transferred to SAM. Federal Agency Registration (FedReg), the Online Representations and Certifications Application (ORCA), and the Excluded Parties List System (EPLS) also will be migrated into SAM. One advantage to the creation of SAM is that it will reduce the number of passwords users need to remember, reduce the number of systems needed to enter and interact with, and reduce data redundancy by sharing the data across the award lifecycle.
July 16, 2012 by cs
Do government purchasing departments drown prospective vendors and contractors in paperwork and procedures?
“I certainly believe there is too much red tape in selling to the government, which is driving up procurement costs on lower ticket items, which is the core of our business,” Steven Bosio, president of Grand Rapids, Mich.-based MarketLab, told Industry Market Trends (IMT). MarketLab is a direct-mail catalog supplier of specialty products and services for health care professionals.
Keep reading this article at: http://news.thomasnet.com/IMT/2012/07/10/cutting-through-red-tape-in-government-procurement/
May 21, 2012 by cs
At 4:30 pm on May 21, 2012, GSA issued the following announcement delaying the implementation of the new SAM system:
The General Services Administration (GSA) is moving the implementation date of the System for Award Management (SAM) from May 29, 2012 to end of July 2012. The additional sixty days will allow federal agencies to continue preparing their staff, give agencies and commercial system providers even more time to test their data transfer connections, and will ensure SAM contains the critical, documented capabilities users need from the system.
This first phase of SAM will include the capabilities of Central Contractor Registration (CCR)/Federal Agency Registration (FedReg), Online Representations and Certifications Application (ORCA), and the Excluded Parties List System (EPLS).
In preparation for the launch, GSA conducted extensive testing internally and in coordination with federal agencies using the data from these systems in their own contracting, grants, finance, and other departments. The testing was very valuable and will focus the efforts of the next sixty days.
SAM will reduce the burden on those seeking to do business with the government. Vendors will be able to log into one system to manage their entity information in one record, with one expiration date, through one streamlined business process. Federal agencies will be able to look in one place for entity pre-award information. Everyone will have fewer passwords to remember and see the benefits of data reuse as information is entered into SAM once and reused throughout the system.
March 31, 2012 by cs
The U.S. Dept. of Agriculture (USDA) officials has issued a warning that fraudulent letters are being sent by FAX to individuals and businesses in at least four states.
The letters purportedly come from a USDA procurement officer and seek personal information. USDA says these letters are false and in no case should a recipient respond with personal and financial information. The fraudulent letters bear USDA’s logo and seal and are signed by an individual identified as “Frank Rutenberg” using a title of “Senior Procurement Officer.”
Letters have been received by FAX in Alabama, Nebraska, Pennsylvania and Wisconsin, but may have also been sent to other states.
It’s possible that the mailing list for the fraudulent letter is being derived from public information in Central Contractor Registration (CCR).
Recipients should not respond and should not supply the requested information. USDA is investigating this matter through the Office of the Inspector General.
If you suspect you have received such a letter or have questions please contact USDA at: firstname.lastname@example.org or call 202-720-9448.
Visit the FTC’s Identity Theft site to learn what to do if your identity is stolen: http://www.ftc.gov/bcp/edu/microsites/idtheft.
March 19, 2012 by cs
Perhaps for as long as the federal government has reported which of its contracts have been awarded to small businesses, critics have charged that many of those contracts have actually gone to large companies — often very large companies.
Recently, the American Small Business League, perhaps the loudest of those critics, tried to outline the scope of diversion. The association issued a report that studied the 100 companies that won the most federal small-business contract dollars in 2011 and found that at least 72 of them either had too many employees or too much revenue to be eligible for government assistance to small business. (S.B.A. size standards vary by industry and sector, but generally a company must have fewer than 500 employees or less than $7 million to be considered small.)
The federal government, the world’s largest buyer of goods and service, is obliged by law to try to direct 23 percent of its purchases to small businesses, though there are no penalties for failure. The government hasn’t reached that goal in years, and while recording a deal with a bigger business as a small-business contract — whether by mistake or by fraud — does not necessarily mean that a small company has been denied an opportunity, it does exaggerate the government’s contracting achievement. In the view of Elliott Rosenfeld, of the league, said that in turn undermined the case for stronger enforcement of contracting rules. And by inflating an agency’s sense of achievement, it could weaken the agency’s drive to award more contracts to small businesses.
S.B.A. officials, for their part, insist the league’s analysis is premature. This summer, the S.B.A. will release its own report on the government’s contracting efforts in 2011, said a spokeswoman, Hayley Meadvin, after spending months reviewing the records. “By the time we release our fiscal year report, we have corrected these mistakes,” she said. “We spend a lot time making sure our data is as clean as can be.”
Moreover, the league has been prone to sweeping accusations. The group called this latest report, for instance, “strong evidence that large companies are the fraudulent recipients of the majority of federal small-business contracts every year.” But even if improperly coded contracts are as pervasive as the association claims, is it necessarily the result of fraud?
The Agenda decided to look at one large company, mentioned incidentally in the report, that won small business contracts in 2011, to try to find out: The New York Times Company. The Times was not among the league’s list of 100; it was identified as one of 55 well-known corporations that received small-business contracts last year when it sold $56,821 worth of newspapers to the United States Military Academy at West Point, N.Y. — 500 daily subscriptions for the 28 weeks school is in session, according to Carol D’Andrea, The Times’s circulation manager for sales to schools and colleges.
In the government’s record of the West Point transaction, known as a contact action report, The Times is described as having $3 billion in revenue — and 10 employees. (Both figures were wrong: in 2011, the company’s revenue was $2.3 billion and the work force totaled 7,273 employees, according to the most recent annual report.) In a field labeled “Contracting Officer’s Business Size Selection,” the document describes The Times as a “small business.” Under government size standards, newspaper publishers must have fewer than 500 employees to be considered small.
Our inquiry began with a call to West Point. The contracting officer who approved the deal, Kathleen Judson, said in a brief interview that she had not designated The New York Times as a small business. “The only way that could have happened is that it must have been prepopulated,” she said. “Sometimes the fields come through on the contract action report prepropulated. I know The New York Times is a large company.”
Here’s where it starts to get complicated — and government officials contacted by The Agenda offered little help in clearing up the confusion. S.B.A. officials spoke authoritatively about the agency’s efforts to correct contracting records, but referred our questions about how those records are created to the General Services Administration, which oversees the procurement infrastructure used across the government. The G.S.A.’s deputy press secretary, Adam Elkington, initially sent us to the Army for answers, then later promised to find us a colleague who could answer basic contracting questions. (He never did.) A spokesman for West Point, Frank DeMaro, wrote down our questions but did not answer them. Eventually, Daniel Elkins, a spokesman for the Army’s Mission and Installation Contracting Command at Fort Sam Houston, in Texas, fielded some of our queries.
This is what we know: every entity selling to the government must sign up with the G.S.A.’s Central Contractor Registration with a unique identification number, known as a DUNS number, from Dun & Bradstreet. The vendor supplies its annual revenue and employee headcount for the entire organization, which the S.B.A. uses to determine whether the entity is a small business. What complicates things is that companies must register each legal division, or any office with a separate location or address separately. The New York Times currently has at least three active contractor registrations. One of these was set up by Ms. D’Andrea and her colleagues in The Times’s Education Sales department in order, she said, to sell the subscriptions to West Point.
The Times is not identified as a small business in the Education Sales department’s registration. It turns out, though, that West Point did not use this registration to pay The Times. Instead, the contract refers to the DUNS number used by another registered Times Company entity, this one made by the TimesCenter, an event hall at the company’s headquarters on Eighth Avenue. In that registration, The Times did identify itself as a small business.
A Times Company spokeswoman, Eileen Murphy, said by e-mail that the employees who initially registered the TimesCenter were no longer employed there. But, she said, when the TimesCenter first opened, “it was operated as an independent business, separate from The New York Times Company. It is possible that the small-business designation was one that fit at the time, but again, we do not know for sure.” Ms. Murphy said she did not know whether the TimesCenter was independently owned at the time or just operated as if it were. Today, she said, it is operated as part of The New York Times. Nor could she say whether, or why, a Times employee entered the inaccurate revenue and headcount figures.
At West Point, neither Ms. Judson or Mr. DeMaro have explained why Ms. Judson used the registration from the TimesCenter rather than the one from the Education Sales department. (In an e-mail, the Army’s Mr. Elkins said “multiple actions between the N.Y. Times registration of DUNS numbers and contracting officer actions makes it difficult to identify the exact sequence of events.”) But Ms. Meadvin of the S.B.A. disputed the claim that the business size field was automatically filled in, saying, “to our knowledge” it is “the only field that is manually entered.” Mr. Elkington of the G.S.A. did not respond to our request seeking clarification.
In any event, government contracting officers like Ms. Judson are not supposed to rely on information from the Central Contractor Registration to determine whether a business is small — the registration record says as much at the very top. Instead, they are obligated to verify size, or any other claims a company makes, with a separate database known as the Online Representations and Certifications Application, or ORCA — which imports size information from the Central Contractor Registration. (Filling out this form, Ms. D’Andrea said, “is worse than filling out your taxes. Just the password is 16 digits and you can’t have repeating letters and numbers.”)
However, while the Education Sales department submitted an ORCA form — and did not claim small-business status — the TimesCenter, the entity on the contract, never did complete the form. According to Mr. Elkins of the Army, “Before the contracts were awarded, the contracting officer observed that there were no Online Representations and Certifications Application records for The New York Times.” The officer then tried to verify The Times’s size, Mr. Elkins said, by turning to yet another database, the Dynamic Small Business Search maintained by the S.B.A., “using the DUNS that was initially provided by The N.Y. Times.” But, said Mr. Elkins, “this procedure was improper and led to the miscoded award; the Army should have asked for this information from the N.Y. Times, rather than relying upon the D.S.B. search engine.”
But if a record for a Times entity existed in the Dynamic Small Business database last year, it is gone now, and this explanation raises additional questions. Which DUNS number did The Times provide to the Army — the one that ended up on the contract, from the TimesCenter, or one from the education sales department? Moreover, if Ms. Judson knew The Times was in fact a large business, why would she conduct a Dynamic Small Business search in the first place? Finally, the actions described here suggest Ms. Judson did in fact have to manually enter the vendor’s business size in the contract, as the S.B.A. has maintained. (Mr. Elkins has not responded to requests for further explanation.)
As it happens, three other federal agencies have used the TimesCenter registration as the basis for contracts in recent years — apparently erroneously, since these agencies were buying newspaper ads, not renting out an event space — and in most of those contract action reports, The Times is described as “other than small.” And yet, for one contract with the Securities and Exchange Commission, The Times was again deemed a small business. The contract officer in that instance referred the Agenda to the S.E.C. press office to set up an interview, which a spokesman has thus far declined to do.
And that’s as far as we have been able to get. We still can’t say with certainty how The Times ended up with a small-business contract. What we did find was a record-keeping system so complex that it invites confusion and error from all parties. “We hear from our small-business members that navigating the federal marketplace is extremely confusing and complex,” said Molly Brogan, a spokeswoman for the National Small Business Association, an advocacy group based in Washington. “Perhaps some level of simplification — along with enhanced oversight and repercussions for those that knowingly miscode a large business as small — would alleviate some of these issues.”
Things may improve this year, when the G.S.A. is to merge the two separate contractor databases into one as part of a bigger move to consolidate all of the different systems — nine of them! — that constitute the government’s “Integrated Acquisition Environment.” According to Ms. Meadvin, the S.B.A. believes that eventually the system will operate the way the people at West Point seem to believe it already does: business size representations from ORCA will be among the data automatically entered into the contract action report.
But for now, small-business advocates bemoan a system that allows everyone involved to evade responsibility for their actions. “The ‘pass the blame’ game you’ve seen from the S.B.A. and the Army is highly indicative of a lack of accountability by the federal employees whose duty it is to ensure that the contracting process is handled professionally and fairly,” said Mr. Rosenfeld of the league. “The erroneous entry into C.C.R. by The Times is also an example of how a large company’s negligence can contribute to the problem.
“Contract error and mismanagement amounts to tens of billions of dollars’ worth of contracts a year being diverted away from small business,” he added. “With such faulty standards of oversight, accountability and transparency, we wonder how easy it must be to hide fraud in the federal contracting process.”
– by ROBB MANDELBAUM, The New York Times, Mar. 15, 2012; this article appears at http://boss.blogs.nytimes.com/2012/03/15/how-the-new-york-times-became-a-small-business.
February 16, 2012 by cs
Almost every proposal you write has a requirement for information on past performance. The government uses this information to evaluate how well your company has performed on similar programs and expects your past performance to be a predictor of how well you will perform on the program you’re currently bidding.
Because past performance can be an important discriminator in the evaluation and selection process, there are some things you should know about how to write your past performance response.
Past performance versus past experience
Past performance comprises a set of specific contracts that you select to demonstrate how well your company, or your team, has performed on contracts that are similar in size, scope, and complexity to your current bid.
Past experience, which is sometimes confused with past performance, is about the broader issue of what experience and expertise the bidding organization has gained from all of its contract work and the work of its teammates.
Select contracts to demonstrate past performance
Past performance is all about relevancy and how well you performed the work you’re referencing. The government will consider these two factors together when developing your past-performance score — and both are important. However, performance is more important than relevancy. It is better to showcase your best-performing contracts and argue that they are relevant than to select contracts that are highly relevant and had poor performance.
Expect the government evaluator to ask your customers how well you did performing each contract. Typically, this happens via a formal past-performance questionnaire submission process and/or direct communication from the government evaluators to your customers. The government keeps two databases—the Contractor Performance Assessment Reporting System (CPARS) and Past Performance Information Retrieval System (PPIRS)—to determine how well your company performs its contracts.
Government access is restricted to those individuals who are working on source selections, to include contractor responsibility determinations.
With the CPARS, companies can regularly review their own ratings for each evaluated contract, but cannot check ratings for other companies. In order to access PPIRS information, a contractor must be registered in the Central Contractor Registration (CCR) system and must have created a Marketing Partner Identification Number (MPIN) in the CCR profile. Because past-performance ratings are such an important factor in proposal evaluations, every company should regularly review its CPARS ratings and challenge any evaluations they consider unfair.
Write your past performance summary
Each RFP will be very prescriptive about the information you need to provide when you describe each past-performance contract. While it may seem obvious, you really do need to provide all the requested information in order to submit a “compliant” proposal (see my Washington Technology article, “6 reasons your proposals fail,” October 2011).
You’ll be asked to provide information to show contract relevance, so keep this in mind when you write your response. Measures of relevance include contract size, scope and complexity, as well as the technical scope of work performed.
The description of the work is where you can stand out. Write your response to not only show that you performed relevant work — which every bidder does — but that you also had specific accomplishments that were meaningful to the government. Don’t just parrot back the statement of work from the contract you are citing. Focus on accomplishments because it’s these achievements that can make your contract past performance stand out from the crowd.
Most importantly, make sure you have outstanding past performance on the contracts you present. Confirm this information with your customers and with your teammates’ customers before you submit your proposal.
The government will read what you write, and they will validate the content. A good writer can present your past performance in a credible, compelling way, but if the underlying performance is less than desirable, it’s hard to overcome the truth.
About the Author: Bob Lohfeld is the chief executive officer of the Lohfeld Consulting Group. This article was published by Washington Technology on Feb. 10, 2012 at http://washingtontechnology.com/articles/2012/01/30/insights-lohfeld.aspx?s=wtdaily_130212.