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September 24, 2020 By cs

Comments on government supply chain rule push for better definitions and more time

Industry groups and other comments highlight the difficulty of complying with a provision of last year’s defense authorization act that requires the removal of products from companies including Huawei and ZTE. 

The broad, ambiguous language of Congressionally-mandated rule for government contractors to remove products and services from companies that pose threats to national security is complicating implementation, according to public comments.

The comment period for the interim Federal Acquisition Rule implementing Part B of Section 889 — a provision of the 2019 National Defense Authorization Act — closed last week, and the more than 30 comments submitted raise questions related to fundamental compliance issues.

While in general, commenters agree with the rule’s intent, groups representing industry, including the National Defense Industrial Association, BSA | The Software Alliance, the Coalition for Government Procurement and the Internet Association submitted detailed letters to Regulations.gov outlining compliance challenges.  Nearly all asked for extended timelines for implementation and better definitions for key terms and phrases used in the regulation.

Keep reading this article at: https://www.nextgov.com/cybersecurity/2020/09/comments-government-supply-chain-rule-push-better-definitions-and-more-time/168460/

Filed Under: Government Contracting News Tagged With: acquisition planning, China, Chinese firms, contract planning, cyberthreat, industry, industry feedback, national security, NDAA, planning, requirements, requirements definition, security threat, supply chain, supply chain management, threats

August 25, 2020 By cs

4 lessons from SBA’s $30 million ‘Certify’ platform debacle

Let me know if you’ve heard this one before: An agency hires “experts” to develop an application, spends tens of millions of dollars and the effort falls flat.

This easily could be the story to focus on with Small Business Administration’s Certify.SBA.gov project.

A recent agency inspector general report found the agency brought in U.S. Digital Service experts, spent upwards of $30 million over the last five years to develop the platform only for most of the effort to go to scrap and forcing SBA to basically start over again.

Instead this is a story about perseverance.  It’s a story about lessons learned that every agency should keep in mind. And this is a story that offers an inside view into why federal projects do fail and how simple steps could change the direction of any IT project.

Keep reading this article at: https://federalnewsnetwork.com/reporters-notebook-jason-miller/2020/08/4-lessons-from-sbas-30m-certify-platform-debacle/

Filed Under: Government Contracting News Tagged With: application, beta.certify.sba.gov, certification, Certify.gov, Certify.SBA.gov, IG, mission, requirements, requirements definition, SBA, small business, U.S. Digital Service, USDS

November 26, 2019 By cs

DoD Releases Version 0.6 of its Cybersecurity Maturity Model Certification

The Office of the Assistant Secretary of Defense for Acquisition has released Version 0.6 of its draft Cybersecurity Maturity Model Certification (CMMC) for public comment.

The CMMC was created in response to growing concerns by Congress and within DoD over the increased presence of cyber threats and intrusions aimed at the Defense Industrial Base (DIB) and its supply chains.

The model updates Version 0.4, which DoD released on September 4, 2019, and which we wrote about here. The CMMC establishes the framework necessary for contractors to obtain one of five certification levels necessary to perform work on certain DoD contracts, including those that require the handling of Controlled Unclassified Information. Whereas Version 0.4 merely listed the capabilities, controls, and processes that were expected to apply to each certification level, this version provides some additional discussion and clarification to assist contractors with meeting Level 1 certifications.

DoD has not explicitly asked for comment on this version of the CMMC, and has stated that the updated model is being released “so that the public can review the draft model and begin to prepare for the eventual CMMC roll out.” For this reason, although additional changes are to be expected to the model, contractors should review the general requirements closely to ensure that they are positioned to continue bidding on DoD contracts once DoD begins including a requirement to obtain a specific certification level in Requests for Proposal in Fall 2020.

Keep reading this article at: https://www.insidegovernmentcontracts.com/2019/11/dod-releases-version-0-6-of-its-cybersecurity-maturity-model-certification/

Filed Under: Government Contracting News Tagged With: CMMC, cybersecurity, Cybersecurity Maturity Model Certification, cybersecurity standards, DoD, requirements

August 4, 2017 By AMK

Could ‘microconsulting’ disrupt government contracting?

I have never been a fan of contractor bashing.

I believe there is nothing wrong with making a profit. I do not believe that contractors typically spend their days dreaming up ways to cheat the government. Indeed, I even believe that many contractor employees and managers believe deeply in the missions of organizations they work for, and get satisfaction from helping citizens and society through their organizations’ efforts — an observation I discussed a while back in a blog based on an informal conversation at a Coalition for Government Procurement event.

Having said that, I was a strong advocate even when in government 20 years ago for bringing more suppliers who primarily sold to the commercial marketplace into government contracting. Indeed, at a strategic level one of the main thrusts of the procurement reform efforts of the 1990s was to reduce barriers to entry for commercial firms created by government procurement rules — both in terms of the complexity of the process and some government oversight requirements that were burdensome or expensive for contractors to comply with.

Keep reading this post at: https://fcw.com/blogs/lectern/2017/07/kelman-microconsulting.aspx 

 

Filed Under: Government Contracting News Tagged With: acquisition reform, commercial products, competition, microconsulting, micropurchase, past performance, procurement reform, regulatory reform, requirements

October 6, 2016 By AMK

Changing the role of contract managers

The role of today’s “contract manager” continues to change. How and why it is doing so depends on one’s perspective, but from the private to public sector it is converging.

fischetti-ncmaAt the federal level, contract managers develop and manage contract vehicles between both parties; interpret and implement the myriad laws and regulations required for inclusion; provide sound business advice in the execution of pre-award and post-award functions, use a wide range of common contracting methods and contract types; develop and/or review complex pricing arrangements; conduct meetings with contractors on sensitive and/or acquisition-related issues as an authoritative contractual representative when warranted; assist in the procurement of standard or specialized services, commodities and/or construction within a contracting office;execute and track deliverables until final contract closeout, etc. This traditional “cradle to grave” responsibility is (to the extent it wasn’t already) a growing role at the state and local public procurement level as well.

Some government organizations, or the contract managers themselves, view their role as compliance and process enforcement, while others see it as much more. However, in going beyond traditional roles, should contract manager involvement start much earlier and be more comprehensive, including requirements definition, acquisition strategy and planning, spend analysis, source selection, supply chain management, project management, and the external relationships from beginning to end?

Keep reading this article at: http://www.federaltimes.com/articles/changing-role-of-contract-managers

 

Filed Under: Government Contracting News Tagged With: acquisition planning, acquisition strategy, acquisition workforce, project management, requirements, requirements definition, source selection, spend analysis, supplier relations, supply chain management

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