Government Contracts, Investigations & International Trade Blog : Government Contracts Lawyer & Attorney : Sheppard Mullin Law Firm : Bids, Licenses, Awards, Conflict of Interest.

By John Chierichella and Jonathan Aronie

Note: The following post is adapted from the forthcoming 2012/2013 GSA Schedule Handbook, published by ThompsonWest, due out later this year.

The past 12 months were interesting ones for the Multiple Award Schedule Program. To the dismay of many, and the embarrassment of some, the General Services Administration seems to find it hard to stay out of the press these days.

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By Alexander Major

A year ago, we advised our readers of the interim rule intended to emphasize competition under GSA Federal Supply Schedule (“FSS”) contracts and FSS Blanket Purchase Agreements (“BPAs”) here. To recap, the March 2011 interim rule imposed a requirement for varying degrees of competition for orders above the FAR’s $3,000 Micropurchase Threshold depending on the type of order being placed (i.e., with or without a statement of work (“SOW”) or placed under a multiple award BPA). The final rule becomes effective April 2, 2012.

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By Jonathan S. Aronie

So there I was, just sitting there minding my own business. It was the third day of the GSA OIG’s site visit being conducted as part of a routine pre-award audit (or as the OIG called it, a pre-award “attestation review”), and all was going well. The auditor, who was quite a nice guy frankly, had had many questions, as was to be expected, but nothing for which this particular mid-sized GSA Schedule contractor did not have a reasonable response. No Price Reductions Clause violations. No overbillings. No resume qualification issues. Overall, a pretty darn good preliminary report if you ask me. But then, out of the blue, he says, “okay, I’d like to interview your personnel now.” Interview my personnel?! Come again!?
 

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By Alexander Major

On March 16, 2011, the FAR Councils, heeding Congress’ mandate in Section 863 of the 2009 Defense Authorization Act, published an interim rule intending to ramp up competition for orders placed under GSA Federal Supply Schedule (“FSS”) contracts and FSS Blanket Purchase Agreements (“BPA”). The new rules, which apply to all federal agencies as of May 16, 2011, instill varying degrees of competition to orders above the FAR’s $3,000 Micropurchase Threshold depending on the type of order being placed (i.e., with or without a statement of work (“SOW”) or placed under a multiple award BPA). The attached matrix, prepared by Jonathan Aronie, co-author with John Chierichella of the GSA Schedule Handbook (West 2010), provides a useful summary of the new rules. 
 

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