Where’s My DUNS?

Can’t find your DUNS Number on SAM?decorative image

Are your searches using your DUNS as a filter no-longer working like before?

If you’re registered on SAM.gov, that’s all part of the plan. As of April 4th, 2022, your DUNS number is, well, done.

GSA has eliminated using your DUNS number for any official action and has already issued you a ‘Unique Entity ID’ or UEI.

What’s the difference? Well, that’s a good question. We wrote about this in Feb 2020:  DUNS is DONE (clientviewconsulting.com)

Essentially, the DUNS number is issued by a commercial entity and GSA preferred to issue their own identifier for improved accuracy, services, etc.

If you search using DUNS numbers, you need to change your filters to use the UEI. More importantly, your UEI is now your official identifier on all government transactions.

You can read all the details on the SAM.gov website

For SAM Administrators, it’s worth looking at the SAM.gov ANNOUNCEMENTS section on their home page as there are five separate announcements about the new UEI.

Enjoy your new identity!

Congress Reaches Deal on the FY22 Omnibus Bill

decorative imageAfter six months Congress finally reached a deal on the FY22 Omnibus Budget. Released this morning, the “Consolidated Appropriations Act, 2022” provides $1.5T to fund our government for the remainder of the fiscal year – that is through Sep 30th, 2022.

For those interested in Defense, the DoD’s unclassified budget will be $780B. Domestic budgets have increased substantially over FY21.

The bill still needs to be approved by both the House and Senate, and Congress has until March 11th to pass this bill, otherwise they’ll need an additional CR (continuing resolution). According to The Hill lawmakers are considering adding an additional four days to the current CR to ensure the bill passes without running into the current deadline.

You can read the full text, and any of the associated explanatory notes (i.e., where the money is…) here:

Bills This Week – Home (house.gov)

If you want to read The Hill’s reporting you can see it here:

Lawmakers reach $1.5T deal on government funding package | TheHill

Breaking Defense Reports the DoD has stopped implementing Contractor Mandatory Vaccinations

In a story published today, Breaking Defense reports the DoD has issued a memorandum dated Dec. 9th, 2021 instructing contracting officers to stop enforcing President Biden’s Sep. 9th Executive Order imposing vaccine mandates on defense contractors. Citing an earlier report from Politico, Breaking Defense quotes Pentagon spokeswoman Jessica Maxwell, who has “…acknowledged that the department has “provided guidance to contracting officers to ensure compliance with the court order and instructed contracting officers not to enforce the vaccination mandate at this time,” she said in a statement.”

President Biden’s Executive Order has created consternation and confusion regarding which contractors and which employees are covered. All government contractors with contracts valued at $250,000 or more are effectively impacted by this Order. Multiple lawsuits have been filed across the country and a Federal District Court Judge in Georgia issued an injunction stopping its implementation on December 7th, 2021.

You can read the entire story here:

Pentagon stops implementing vaccine mandate for defense contractors – Breaking Defense Breaking Defense – Defense industry news, analysis and commentary

SAM.gov Wants to Get to Know You Better. Much Better.

Dear SAM.gov Administrators,Decorative image of cyber lock

Like Your Privacy? Want to be a Government Contractor? Take your pick…because these are now mutually exclusive choices.

NextGov reported last week that the Government Services Administration (GSA), which operates everyone’s favorite data aggregator, www.SAM.gov, is going to require every entity registered to provide the name of a real human being as the Account Administrator.

Apparently there are fake accounts and / or false names being used for SAM.gov registrations.

You may recall that SAM.gov started requiring all entities to submit notarized certification letters to establish or renew a registration a few years ago.

Then we all had to create a new account via www.Login.gov and use those credentials to access SAM.gov.

Apparently, that wasn’t sufficient so now they’re requiring each SAM Account Administrator to provide a copy of their driver’s license, social security number, and a valid phone number. The data will be cross-referenced with the issuing agency for validation.

Oh, and GSA says they won’t store the data either in SAM.gov or Login.gov.

The rollout started on October 1st this year – but apparently there isn’t yet a hard deadline established.

So, SAM Account Administrators take note and prepare to sacrifice a bit more of your personal info.

Read the full article if you want to know more.

Expect the 20+ Year Continuing Resolution Streak to (WAIT FOR IT…) Continue in 2021

It is September, the last month of the Government’s fiscal year. This means many things for those whose livelihoods depend on the U.S. Federal Government.

Government personnel, especially those in contracting, budgeting, and program management, are busy trying to obligate and / or disperse funding before appropriations limits kick in. This means no new program starts are likely, as the focus is on awarding task orders and cleaning up end-of-year business.

For Government Contractors, it also means an increased challenge in getting the attention of key Government personnel to conduct business development activities – because these same people are caught up in the September frenzy.

But the big issue at play is whether Congress will pass all 12 major appropriations before September 30th — recent history shows this to be unlikely.

Since 1997, Congress has never – let me say that again – never passed all 12 major appropriations bills by the deadline. Continuing Resolutions (CRs) have been utilized for at least one appropriation bill each year since 1997. According to an analysis of Congressional Research Service-produced CR data by the Peter G. Peterson Foundation, Congress has used CRs more than 124 times covering each FY since 1998. That’s an average of five CRs per year since.

Without a budget, congress must pass a Continuing Resolution, which is a temporary stopgap spending bill that allows the Government to continue operating at prior fiscal year budget levels until a full budget is passed. CRs can be government-wide or aimed at specific appropriations – such as defense, agriculture, health and human services, etc.

Many news outlets that cover Capitol Hill have indicated that a CR is likely this year – especially for the annual defense appropriation.  In fact, the Senate Appropriations Committee’s subcommittee on defense issued a statement in July indicating that a defense bill isn’t likely until December.

What does this mean to you?

  • New Start Programs — if you are expecting a contract award for a new start program to occur before January 1, 2022, you may want to begin adjusting your planning activities to the right
  • Existing Programs — funding normally begins to flow in November and December if appropriations bills are passed on time; but in a CR, funds may not flow until January or February because funding levels are prioritized and meted out in monthly allotments aimed at continuing operations, which are prioritized over contracts

SAM I AM (a re-boot)

If you did not like that beta.sam,

Then say so long, let the door SLAM!

Soon sam.gov begins to serve,

Here’s to hoping it performs with much more verve…

Your favorite Government agency – the General Services Agency (GSA) – is finally merging your favorite two websites (beta.sam.gov) and (www.sam.gov) into one platform for all your Government contracting needs.

Effective on May 24th, 2021, both sites will merge (without difficulty, we are sure…) accomplishing the next step in a multi-year consolidation of several Government information / transaction websites such as:

  • Central Contractor Registry (CCR) – now closed
  • Federal Procurement Data System (FPDS) – now merged
  • Federal Business Opportunities (FBO.gov) – now closed
  • Funding Accountability and Transparency Act (FFATA) – soon to merge
  • Electronic Subcontracting Reporting System (ESRS) – soon to merge
  • Wage Determination Online (WDOL) – soon to merge

And, just because they can, GSA is also releasing a revamped www.sam.gov website on April 26th, 2021.

If you are curious to see how things will look before the release date – here is a link to a pre-release guide available from the Federal Service Desk (yes, it is another GSA website):

https://www.fsd.gov/sys_attachment.do?sys_id=6d9521581b3e28902fe5ed7ae54bcb5d

For many of these websites, if you want to access certain features, you may need credentials issued by Login.gov – also a GSA website. You can sign up at www.Login.gov.

Of course, as a current Government contractor, you likely have already done so.

Writing High-Scoring Proposal Responses within Severe Page Limitations

Government evaluators have arduous jobs. When assigned to a Source Selection Evaluation Board they’re tasked to read and score several proposals to select the right contractor. Depending on RFP Section L and M requirements – that can amount to reviewing hundreds, if not thousands, of pages, in addition to fulfilling their ‘day jobs.’ This is one reason why the Government smartly sets page limitations,, much to the chagrin of contractors, who are often challenged to be compliant, never mind compelling.

I remember one customer’s struggle with a particularly challenging proposal. Volume II was to include an Executive Summary, Management Capabilities, Experience, and a Technical Approach within 75 pages at 12-point font. While this may seem reasonable at first blush – it was not. Addressing the Technical Approach was particularly onerous:

  • Per L&M, responses had to demonstrate a “clear understanding, the methodology and flexibility that will be utilized, and how the approach will accomplish all tasks, subtasks, and administrative tasks as are necessary to ensure program success within the required time frame.”
  • High-level technical requirements, part of a 43-page PWS, included 7 Objectives with 36 “Key” Tasks.

Situations like these challenge Subject Matter Experts (SMEs), whose strengths may not include concise technical writing.

ClientView helped by providing a framework to facilitate a succinct, compliant response. Our annotated outline included page limits, simple guidance, and example text that demonstrated how to achieve compliance and a high score within relatively abbreviated page real estate.

We attacked the requirement to address “tasks, subtasks, and administrative tasks” as follows:

Address each PWS Key Task with this outline:

  1. 1-2 sentence Task Understanding
  2. 3-5 sentences on your solution (approach) – discuss HOW you will accomplish the task (e.g., people, process, tools), not WHAT you will do
  3. Proof example – this is brief but replete with quantitative results your solution/approach provided to other customers

Example:

“Conduct inquiries (PWS 3.2, Assess/Plan). Good Voice of Customer (VoC) information is at the heart of successful CPI: without it, organizations risk investing resources in projects and initiatives that do not improve the customer experience – or worse, negatively impact it. With all-inclusive VoC, GOV’T AGENCY [CUSTOMER] is better informed and, therefore, better equipped to prioritize needed process improvement.Adding Value -Conducting Inquiry

Typically, inquiries regarding CPI initiatives are conducted via impersonal “paper” methods. COMPANY X’S approach includes face-to-face interviews, led by KEY PERSON, geared toward engaging GOV’T AGENCY customers as integral process improvement team members. If a particular stakeholder is unable to commit in-person, COMPANY X uses a variety of classical organization- and process-level VoC identification methods (e.g., surveys, focused telephone interviews, Kano model-based inquiry, CTQ tree development, and Quality Function Deployment matrices) to ensure we are continually working on meaningful projects.”

By following this template, the SMEs were able to focus on crafting language that 1) addressed the Government’s requirements, 2) was scorable, and 3) avoided unnecessary elaboration.

Having trouble being compliant, compelling, and succinct? Give us a call – we can help.

If Necessity is the Mother of Invention, Then Crisis Breeds Ingenuity (and BOY DO WE NEED IT!)

COVID-19 is indiscriminate in its damage — to both our public health and our economy, no person or business is immune to its debilitating effects. Yet, much like a phoenix rising from the ashes, SOME small businesses have held their own, or even prospered during the current economic crisis. How? Consider the story of a New York City hotelier with an interesting take on how small businesses have responded to the challenges of 2020-2021. In his view, you do not get through a crisis by being stronger, you get through it by being different. He adapted his business model to meet the new needs of his clients. With New York City restaurants and attractions suddenly largely unavailable, he, “…transform(ed) the hotel into a fantastical place completely removed from the grim reality outside.” He made his hotel the destination rather than just a stop on the itinerary. And his hotel did not shutter.

There is reason to hope that normal life and business practices will resume with the vaccine roll out in progress. Yet does anyone imagine that we will simply pick up where we left off in early 2020? It is more likely that those who have successfully navigated small business challenges through the pandemic will again need to adapt in the aftermath of COVID-19. Unknown circumstances post-COVID promise to be just as impactful and risky to our businesses as was the onset of the disease. Having made all the adaptations required for our employees and ourselves to work safely and effectively, when do we return to our old business models? Or do we ever? As we contemplate these questions for ourselves, all of our partners, competitors, associates, and clients will be thinking them through as well. There will be new opportunities as well as risks, and those of us with our eyes open and who are prepared to be different – again – will thrive.

Phishing, Malware, State Sponsored Hacks…DoD Demands Data Security from its Government Contractors

According to some estimates, more than 70% of DoD data resides on contractor networks. Given the ever-growing security risk posed by cybercriminals, the DoD has developed a new set of standards called Cybersecurity Maturity Model Certification (CMMC) to help protect Government contractors and their data from cyberattacks.

What is it?

CMMC is a new certification that addresses the cybersecurity processes used by contractors and subcontractors to perform work on Government contracts. The certification process assesses a contractor’s cybersecurity procedures and practices with respect to defined levels of maturity (CMMC Level 1-5). The assessment is conducted by an outside third-party assessment team.

Why is it Important?

In a word – hackers. As we see in the news every day, commercial companies, state, and federal Government agencies (including DoD) are continually being targeted by hackers – individuals, criminal organizations, or nation state actors. Just recently – on Dec 13th, 2020 – the U.S. Treasury admitted it had been breached by a foreign government backed cyberattack. Government data is targeted and exploited, so safeguards must be implemented and updated to stay ahead of threat actors. CMMC seeks to ensure that Controlled Unclassified Information (CUI) and Covered Defense Information (CDI) is adequately protected.

Who is affected?

Basically, all contractors and subcontractors that work on DoD programs will be required to have some level of certification (at least Level 1). Each contract will specify the CMMC level required for the prime contractor and subcontractors.

What is the timing?

DoD released the initial set of CMMC standards on January 31, 2020. CMMC language has already started appearing in Requests for Proposals (RFPs) and Requests for Information (RFIs). The DoD will implement a phased rollout of CMMC with 15 pilot programs in FY2021, increasing in number each year until FY2025. All new DoD contracts will require an appropriate level of CMMC certification by 2026. Existing contracts up for renewal will reflect the CMMC level required by the contracting authority.

What does this mean for me and my company?

CMMC will be implemented soon, so if you currently work, or plan to work, on DoD programs then you need to be ready. Review the initial release of the CMMC standards to gain a comprehensive understanding of its stipulations. Discussions with the DoD agency or prime contractor should give some insight into which level certification may be required for existing contracts. Future RFIs and RFPs will include CMMC requirements. You need to be prepared ahead of time – don’t be excluded from a bid because you failed to meet the CMMC requirements!

Don’t Be “THAT” Company

COVID lockdowns have impacted business development routines. It’s harder now to get in front of your Government customer – which presents a real obstacle to getting noticed. This has given new life to a belief that submitting a proposal is a great way to market to a potential Government customer.

Spoiler Alert: It isn’t.

Marketing is a method of introducing your firm, or an idea, to prospective customers.

Proposals are explicit offers to prospective customers to purchase your solution. In the federal market space, proposals involve substantial effort to prepare, write, and present your approach in a specific format for a given opportunity.

As you can see, marketing and proposals are nothing alike – yet some people and companies seem to believe that one can serve as the other. Here’s why marketing strategies and proposal submission are not interchangeable:

If you submit a proposal against a Request for Proposal (RFP), then the Government is obligated to review and rate your proposal against a specified set of criteria. If the RFP is issued under the Federal Acquisition Regulations (FAR), then the reviewers must evaluate, score, and report on your proposal according to their acquisition plans. Afterwards, you are entitled to a debriefing based on their review, whether you win or not. This review and selection process takes a substantial amount of time, resources, and multiple layers of review from the contracting, legal, technical, and program management personnel involved. It is not light work and typically takes several weeks to complete; it can be arduous.

So, imagine, if during their review it becomes clear to Government evaluators that your intent was to ‘introduce’ your firm to them for the ‘next opportunity.’ Are they likely to be impressed and tell one-another – ‘Hey, if only XYZ firm had been able to do this work …” or “I can’t wait for XYZ’s next proposal”?

Spoiler Alert: They won’t.

Their impressions are more likely to be one or more of the following::

  • Incredible – XYZ had no clue what they were doing
  • Wow – there goes three days I’ll never get back
  • I hope I never see a proposal from XYZ again
  • Why would XYZ think that we’d want their solution … when they can’t even follow directions or respond to our actual requirements?

Government evaluators are looking for serious competitors that understand their requirements and can offer a solution that can solve problems they have now. They spend months preparing detailed solicitations explaining exactly what they need and expect to receive serious proposals in return.

If you really want to impress your prospective customer – take the time to learn about their needs and challenges and begin a relationship. Send them a thoughtful, detailed white paper sharing your ideas and detail how those ideas might benefit them. You can even submit the white paper instead of a proposal – and explain to them that you cannot submit a proposal now but want to get their attention.

They’ll appreciate your honesty and your respect for their time. Now, they can set aside your White Paper for a more appropriate time and look at in proper context – and your efforts to be noticed won’t gain your company the wrong kind of attention.