Guidance and Support for Government Contractors

By: s.m.amend | December 29, 2017


Further guidance regarding cyber security compliance has been provided by Ellen Lord, the Defense Undersecretary for Acquisition, Technology, and Logistics. The January 1, 2018 deadline for being 100% compliant has been relaxed to now “the only requirement for this year is to lay out what your plan is” said Ms. Lord in a briefing given on December 7, 2017. She goes on to say “that can be a very simple plan.” So, perhaps cyber security is not as scary as it initially seemed!

 

Don’t get too comfy thinking you can put off cyber security a little longer. This clarification still requires contractors to have a System Security Plan by December 31st.  Your System Security Plan describes the current state of your information system and out...

By: s.m.amend | September 12, 2017

The Department of Labor issued a memorandum that increased the Health and Welfare Fringe Benefit (H&W) back in July. For any contracts issued after August 1, 2017 that are subject to the Service Contract Act (SCA), you need to be aware of the increased rates.  The two notable increases are:

SCA H&W Rate: $4.41 per hour

SCA H&W Rate for employees performing under contracts covered by E.O. 13706 ("Establishing Paid Sick Leave for Federal Contractors") : $4.13 per hour

By: s.m.amend | September 12, 2017

Did you know that over the summer there was a class deviation to the definition of the micro-purchase threshold?  Most people didn't! Unless you are keen on reading FAR Part 2 daily, you may have missed this deviation.


Class Deviation- 2017-O0007, Increased Micro-Purchase Threshold. This clause deviation is effective on Sept 01, 2017, and remains in effect until incorporated into the DFARS, or until otherwise rescinded.

“Micro-purchase threshold,” means $5,000 (10 U.S.C. 2338), except it means-

    (1) For DoD acquisition of supplies or services for basic research programs and for activities of the DoD science and technology reinvention laboratories, $10,000 (10 U.S.C. 2339);

    (4) For acquisitions of supplies or services that, as determined by ...

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.” (Federalregister.gov).

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.  

Law.Cornell.edu 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...

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