Organizational Structure of the Department of Defense (March 2018)
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This APEX Accelerator is funded in part through a cooperative agreement with the Department of Defense.
The FY2018 NDAA increases Micro Purchase threshold to $10,000 (from $3,000). Total Simplified Acquisitions Purchase (SAP) threshold is now $250,000 (from $150,000)
This can be a gamechanger for small businesses trying to get a “foot in the door” with federal agencies; the government customers now have a mechanism to pave the way for a streamlined, simplified way to award contracts. Micropurchases are small business set-asides by default.
Read the Civilian Agency Acquisition Council memorandum to agencies – Appendix 2 outlines which FAR clauses are affected by the change.
A great summary and explanation by Matthew Moriarty at SmallGovCon Law
Note: the FAR has not been updated yet, so agencies have to use a “class deviation” to avail themselves of the newly adjusted ceilings.
Currently, here’s the summary according to the SBA
Virginia Department of Small Business and Supplier Diversity (SBSD) reviewed the list of certified and pending Small, Women, and/or Minority (SWAM) companies. They issued a letter to businesses who had an invalid NIGP code (one ending with 000) – the number ending in ‘triple zero’ is a category and not an actual code. Any invalid code(s)/description(s) will be deleted from your profile by February 23rd.
To locate proper NIGP Codes for your company, click here.
EXISTING SWAM Certified Companies: The letter includes instructions on updating your NIGP Codes.
APPLICATIONS PENDING Companies: Do NOT to change the NIGP codes in the electronic application at this point. Doing so will reset the submitted date of their application and result in the 60-business-day waiting period to be reset. To correct the codes, fill out the SWAM notice of change form and send to SBSD, and the agency will update the codes.
January 2018 update on the Dept. of Navy Rapid Innovation Fund (RIF) program: Good news especially for small, innovative companies who want to perform final development and testing and sell the resulting product to the DOD: Section 213 of the FY17 NDAA removed the RIF program sunset clause, providing permanent authority for the program. While the FY18 defense appropriation is still pending, and a RIF plus up is necessary, OSD is gearing up for an FY18 RIF BAA in the Feb/March 2018 timeframe, which will include topics from all the defense services. Typical service-wide RIF funding available is $200-250M. The full BAA schedule and latest info is at http://www.defenseinnovationmarketplace.mil/rif.html.
Government TPOCs can talk openly now; communications become restricted upon BAA release. Historically, about 2/3 of Dept. of Navy RIF awards go to fund projects which derive from the SBIR program. It’s easy to apply for RIF (three page white paper + quad chart), but the competition is quite fierce (~4% of white papers result in a full proposal invite). Interested companies may want to review the FY17 BAA-Amendment 2 (Dept. of Navy topics on pages 45-69) now as many of the topics represent persistent Dept. of Navy needs. This National Defense Magazine article provides sound advice.
Director, Office of Small Business Programs
Office of Naval Research
875 North Randolph St.
ONR Code: 00SB
Attention: Brenda Pickett
Arlington, VA 22203-1995
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Spend enough time at matchmaking events, industry days, networking events and conferences in the #GovCon world, and one could amass quite a collection of Capabilities Statements. If one were into collecting them. Which I am:
The capabilities (or capability) statement is your business’s resume; as such, it needs to combine the technical skillset you’re offering with an attractive format that would cause a neutral third party to pick it up and glance at it. There are plenty of resources (APTAC, HHS, SAP&DC) who will tell you what to put in it. ISI Federal lays it out in a graphical format. FDIC has a whole slide deck. I’d like to take you through a slightly different analysis:
“Who [or what] is it for?”
Is your one-pager ready for prime time? Make sure you’re not guilty of any egregious “Don’ts“. Keep your customer paramount in your mind when you’re writing and designing: will she want to pick it up? Read it? share it? Do you even know who your customer is? If not, do your homework first.
And if you would like some help, contact your local PTAC. We’ve got our red pens at the ready.
You have doubtless heard and read all about the looming requirement for all Department of Defense government contractors to become compliant with Defense Federal Acquisition Regulation Supplement (DFARS) minimum security standards derived from NIST SP 800-171 Rev 1 by Dec 31, 2017- or else risk losing their contracts. DFARS Clause 252.204-7012, Safeguarding Covered Defense Information and Cyber Incident Reporting, will be a mandatory clause in all contracts except for contracts solely for the acquisition of COTS items.
This requirement applies to any DoD Contractor, subcontractor, and supplier ALL THE WAY DOWN THE SUPPLY CHAIN that processes, stores, or transmits Controlled Unclassified Information (CUI). Not just security contractors. Not just companies that have clearances. Not even just IT contractors. If you have a landscaping business and you are performing work at a DOD facility, and have access to blueprints that are or may be considered CUI, you’re subject to this requirement. CUI includes the categories outlined in the NARA CUI Registry, but as you can probably imagine, is not limited to that. your government customer can identify additional categories and data, and you as a contractor, should err on the safe side and identify potential CUI so that you can protect and segregate it just in case.
Note: civilian contractors are not subject to this requirement (there are only 15 security controls outlined in FAR part 52.204-21 compared to 109 in the DFARS clause), but that may be changing to synthesize the compliance requirements to the more complete set that the DOD/DFARS adopted.
Ultimately, it is the contractor’s responsibility to determine whether it is has implemented the NIST SP 800-171 (as well as any other security measures necessary to provide adequate security for covered defense information). Third party assessments or certifications of compliance are not required, authorized, or recognized by DoD, nor will DoD certify that a contractor is compliant with the NIST SP 800-171 security requirements.
The protections required to protect government information are dependent on the information DoD is protecting and the kind of system on which the information is processed or stored.
There is no single or prescribed manner in which a contractor may choose to implement the requirements of NIST SP 800-171, or to assess their own compliance with those requirements. For companies new to the requirements, a reasonable first step may be for company personnel with knowledge of their information systems security practices to read through the publication, examining each requirement to determine if it may require a change to company policy or processes, a configuration change for existing company information technology (IT), or if it requires an additional software or hardware solution.
PTAC counselors can help you walk through these steps. While we’re not technical experts on network security, we could help you walk through the self-assessment and determine what steps you need to take to bring your business up to compliance.
Update (submitted by David Dempsey, Dempsey Fontana, PLLC): This past Tuesday (April 24th 2018), DOD issued draft regulations on its cybersecurity clause DFARS 252.204-7012. Attached are pdf copies of the Federal Register notice plus the two documents referenced in the notice.
PTAC has been advised that DOD has implicitly acknowledged that contractor implementation of a NIST SP 800-171r cybersecurity plan is not going as anticipated. The draft guidance explains three levels of priority within an implemented System Security Plan (“SSP”). The utility of the priority levels is that DOD has identified the priorities on an item-by-item basis per the NIST security requirement. For example, multifactor authentication (NIST 171, 3.5.3) is a priority 1 (“P1”) while monitoring security controls (NISAT 171, 3.12.3) on an ongoing basis is a priority 3 (“P3”). DOD is again focusing on the development of SSP as supplemented by a Plan of Action that includes an implementation schedule.
More importantly, and as highlighted during the presentations sponsored by PTAC, DOD has emphasized that SSPs (with or without an accompanying Plan of Action) will be an evaluation factor used to discriminate among offers as a means to evaluate the government’s overall risk of providing “covered Defense information” to contractors who then use or store CDI on their IT systems. Specifically, the draft guidance states that RFP’s must require delivery of NIST SP 800-171 Security Requirement 3.12.4 – System Security Plan (or specified elements of) and [NIST-171] Security Requirement 3.12.2 – Plans of Action with the contractor’s technical proposal.
Update (submitted by David Dempsey, Dempsey Fontana, PLLC) : Earlier this morning (June 7th, 2018), NIST’s Computer Security Resource Center (“CSRC”) distributed its fourth revision of NIST SP 800-171 (second one for 2018). See https://csrc.nist.gov/ publications/detail/sp/800-171/rev-1/final). As of today, the proper reference to “NIST-171” is NIST SP 800-171 Protecting Controlled Unclassified Information in Nonfederal Systems and Organizations, rev. 1 (December 2016) (updated June 7, 2018) or “NIST SP 800-171, r1 (updated through June 7, 2018).” According to the “errata sheet” the CSRC has made approximately 72 “substantive” changes to NIST-171. Presumably, DOD will revise the link currently set forth in DFARS 252.202-7012 and bring the DFARS clause up to date.
The CSRC also published today three supplemental documents to NIST-171 (available at the above link):
All previous attendees should also be made aware of DOD’s proposed priorities for NIST-171 implementation (see 83 Fed. Reg. 17807 (April 24, 2018) and follow instructions on p. 17808) and the NIST requirements (identified by ¶ number in an Attachment to the slides presented at those seminars. Moreover, DOD’s updated FAQs on NIST-171 implementation (dated April 2, 2108) should be reviewed in the context of today’s revised NIST-171 – see FAQs updated April 2, 2018.
Also included with today’s CSRC announcement regarding NIST-171 is the second draft of NIST SP 800-171A entitled “Assessing Security Requirements for Controlled Unclassified Information (Final Draft)(February 2018). (This document is also available at https://csrc.nist. gov/publications/ detail/sp/800-171/rev-1/final.) The introduction to CSRC’s “assessment” document states that it “is intended to help organizations develop assessment plans and conduct efficient, effective, and cost-effective assessments of the security requirements in NIST Special Publication 800-171, Protecting Controlled Unclassified Information in Nonfederal Systems and Organizations.”
The U.S. Small Business Administration (SBA) updated its Table of Small Business Size Standards adopting the Office of Management and Budget’s 2017 revision of the North American Industry Classification System (NAICS) effective October 1, 2017. The revised NAICS Codes and their corresponding size standards will be available in SAM for use in entity registrations starting October 7, 2017. The updated table of size standards is available now on SBA’s website at www.sba.gov/size.
For more information please contact your Virginia PTAC counselors.
Due to the emergency situation caused by the hurricanes, contracting offices are using authority to waive the requirement for SAM registration in purchases that directly support the emergency response. If you’re helping a vendor who is not yet registered in SAM but needs a CAGE code, the expedited process instructions are below.
(information on selling to disaster response agencies)
Subject: Obtaining CAGE codes for vendors responding to the Hurricanes
Hello everyone – obviously we expect that there will be many offices responding to the hurricanes with emergency purchases where SAM registration is waived per FAR 4.1102(a)(3)(iii) and part 18.102. We want to get the below instructions out for how you can still help your vendors obtain CAGE codes (if they don’t already have one) that are required per FAR 4.1804 for other than micro-purchase actions:
1 – Go to https://cage.dla.mil
2 – Choose ‘Request or Update a CAGE Code’ and hit Begin on the next page
The user will then be taken through a series of pages where they provide the data necessary to set up a CAGE code, but before they get to those elements, they have to answer a few more questions. In order for the CAGE website not to just direct them to go register in SAM, the users need to answer exactly as follows:
From here on, the user is just providing their name, address, etc.information. Should be simple from here.
Be aware – when a user requests a CAGE code be established via this method (instead of through registering in SAM), it goes into manual processing at DLA in Battle Creek. It’s very important that the user enter ‘hurricane’ in the purpose field after they choose other. The CAGE team is going to search for that term in each request that comes in and move those to the top to be worked.
For non-GPC actions, it’s important that the vendor get a CAGE code assigned and it be included in the contract when its distributed to ensure that their eventual payment is streamlined and not held up for manual action. Note also that without a valid CAGE code, an action will fail Procurement Data Standard (PDS) validations.
If these are going to be on-going contracts (such as reconstruction), it would behoove the vendors to eventually actually get registered in SAM (they can use the CAGE code that will be assigned in this process when they do so) even if they’re not technically required to do so because the contract was initially exempted due to the emergency. Being registered in SAM will just make the whole invoicing and payment processes run a bit smoother if the contract lasts for a while.
Lisa Romney, Defense Procurement and Acquisition Policy Office of Acquisition Technology and Logistics
Thank you for the Federal Emergency Management Agency (FEMA) regarding your interest in doing business with FEMA. If you are contacting FEMA seeking to do business in support of a disaster recovery effort, please be aware that in accordance with the Robert T. Stafford Act, FEMA’s goal is to seek local companies within the disaster area for services related to a specific disaster when practical and feasible. The ILP establishes strategic relationships with suppliers and stakeholders; serves as an information provider for suppliers seeking to do business with FEMA; and connects suppliers with program offices in support of FEMA’s mission. The ILP encourages your business to review the information referenced below.
Official Federal Government registration is processed within SAM www.sam.gov . Direct all questions regarding the SAM registration process to the Federal Service Desk at1-866-606-8220.
To get started with your SAM registration, you must have the following:
The Vendor Profile Form can serve as supplemental market research for the agency. Information supplied should not be proprietary or sensitive in nature. Please be specific about how your products and/or services can support FEMA’s mission. Submission of the Vendor Profile Form does not imply a guaranteed meeting or contract award.
*Please click on the following link to access the vendor profile form:Indusry Liaison Program Vendor Profile Form < Caution-https://www.fema.gov/media-library/assets/documents/29748 > and submit the form toFEMA-Industry@fema.dhs.gov < Caution-mailto:FEMA-Industry@fema.dhs.gov >
All meeting requests are at the discretion and availability of the FEMA Contracting Officer, Program Office, and FEMA representatives. If the agency identifies the need to meet to further discuss your company and its capabilities you will be contacted.
We trust that this information will prove helpful. If we may be of further assistance, please contact us at the email address or phone number listed below.
Industry Liaison Program
Business Relations Branch
Acquisition Program and Policy Division
Office of the Chief Procurement Officer
Email: FEMA-Industry@fema.dhs.gov < Caution-mailto:FEMA-Industry@fema.dhs.gov >
Phone: (202) 646-1895