On a March 22 conference call, FAS officials said the refresh could roll out in the middle of April and would include:
Purchasing by non-federal entities from federal supply schedules
Based off an amended General Services Administration Acquisition Regulation, state and local governments will now have expanded buying power in the State/Local Disaster Purchasing Program for disaster preparation, response and recovery.
The new rule also provides MAS access to the American National Red Cross and National Voluntary Organizations Active in Disaster to provide relief and preparedness services.
GSA officials said that vendor participation in the State/Local Disaster Purchasing Program would still be voluntary.
Small business subcontracting changes
Following Federal Acquisition Regulation changes made in November 2016 related to small business subcontracting, FAS will issue several policy adjustments, including:
- Requirements for prime contractors to make good faith efforts to use small business subcontractors during a contract at the same level they were relied on in bidding for the contract.
- Authorizing contracting officers to calculate subcontracting goals in total contract dollars as well as the required goals in terms of total subcontracted dollars. This allows the officers to attribute subcontracts toward total contract performance, including a proportionate share of indirect costs.
- Allowing for contraction officer discretion to call for a subcontracting plan when a small business refiles its size larger than a small business designation.
- Requiring subcontracting plans when modifications to the contract exceed its threshold, even if those modifications still fall under the subcontracting threshold.
- A new requirement for prime contracts with subcontracting plans on task and delivery order contracts to report order level subcontracting info after November. GSA officials said this requirement was not effective until November.
Changes include requiring separate goals expressed in total dollars subcontracted and as a percentage of total planned subcontracting dollars.
Contractors will also assure that after Nov. 30, when reporting subcontracting achievements for indefinite-delivery, indefinite-quantity contracts used by multiple agencies, they will include subcontracting data for each order.
That services offerors will make a good faith effort to “acquire articles, equipment, supplies, services, or materials, or obtain the performance of construction work” from the small businesses that it used in preparing the contract bid.
Assurances that the contractor will provide written explanations to a contracting officer if they fail to acquire the services within 30 days of contract completion.
Assurances that the prime contractor won’t prevent a subcontractor from discussing payment and utilization details with the contracting officer.
Subcontracting plans must include statements detailing whether the offeror included indirect costs in their subcontracting goals, including methodologies for those costs.
Order level changes
Single-award IDIQ contracts intended for multiple agency use will now require order-level reporting.
Order-level reporting requirements after November, when the Electronic Subcontracting Reporting System will be available.
Allows contracting officers to establish subcontracting goals at the order level on IDIQ contracts.
Allows only subcontracting goals established at the order level, not plans.
Service Contract Act/Service Contract Labor Standards wage determinations will also now be updated and incorporated at the schedule contract level.
GSA officials also said Paid Sick Leave policies for federal contractors will also be included in the refresh, which tentatively scheduled for the second week of April.
More information on the MAS refresh can be found GSA Interact.