Guidance and Support for Government Contractors

By: s.m.amend | April 09, 2017

Effective June 15, 2016, the DoD, GSA, and NASA issued a final rule “amending the Federal Acquisition Regulation (FAR) to add a new subpart and contract clause for the basic safeguarding of contractor information systems that process, store or transmit Federal contract information.” (

The new subpart FAR 4.19, Basic Safeguarding of Covered Contractor Information Systems, includes contract clause 52.204-21.  The rule is mandatory, and effective immediately upon contract award or contract modification execution. notes that the clause, “Does not relieve the Contractor of any other specific safeguarding requirements specified by Federal agencies and departments relating to covered contractor info...

By: s.m.amend | March 30, 2017

The General Services Administration’s Transactional Data Reporting (TDR) rule states that contractors must electronically report prices paid by the federal government for goods and services purchased through GSA schedules. Using a phased-in approach affecting select schedules, the TDR pilot program has corresponding reporting requirements that contractors must know.

During the conversion from 72A reporting to the TDR reporting system: For current schedule holders, reporting starts 30 days after the end of the first month of the quarter following acceptance of the mass mod.  New contractor reporting requirements start 30 days after the month of contractor award.

For IFF reporting purposes, contractors are not required to change their cu...

By: s.m.amend | March 20, 2017

General Services Administration’s new Transactional Data Reporting (TDR) rule states that contractors must electronically report prices paid by the federal government for goods and services purchased through GSA acquisition vehicles. ( GSA intends to gain market intelligence about pricing, while improving efficiency and reducing requirements that many contractors found challenging.

TDR is significant not only because of the new reporting requirement, but also because it eliminates the long-standing task for contractors to track their Basis of Award customer’s price reductions, as the new Price Reductions clause does not include a BOA tracking stipulation.

Using a phased-in approach affecting select schedules and SINs, the ...

By: s.m.amend | October 03, 2016

Did you know that if you purchase or subcontract anything under your government contract that you are subject to almost all the same rules as the federal government follows?  By using your contract money to procure goods or services to support that contract, you are using taxpayer money that is subject to many rules and possibly audit. As a government prime contractor, you must know how to properly spend your prime contract money and also reduce your corporate risk.  An audit is something many government contractors will face, if you are caught not spending the money correctly, you could be subject to repaying the government or fines.

The Federal Acquisition Regulation (FAR) is not entirely written for contractors, however contractors that i...

By: s.m.amend | September 07, 2016

New FAR Subpart Requires Government Contractors to Safeguard Information Systems

Over the summer, a new subpart was added to the Federal Acquisition Regulation (FAR) that adds to contractor compliance requirements.  Effective June 15, 2016, GSA, NASA, and the DoD issued a final rule to add new clause and Subpart 4.19 for the protection of contractor information systems that “process, store or transmit Federal contract information.”

The clause applies to any contractor system with federal information; the goal of the language is to be “reflective of actions a prudent business person would employ” and is one of several regulatory measures coordinated with other government agencies to guard information systems.  For exampl...

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