The General Services Administration has been making steady award progress on two signature, multi-award contracts. Even as Polaris II and Oasis-Plus move along, agency appropriations for 2025 look like they’ll be delayed until April, halfway through the fiscal year. For his take on the implications, federal sales and marketing consultant Larry Allen joined the Federal Drive with Tom Temin.

Interview transcript:

Larry Allen Well, Tom, I think the connection is that GSA has done its work to put some of these new contracts in place for buyers to buy more or less about the time that Congress gets around to hopefully passing full FY 25 appropriations. So on the one hand, I think the GSA story is a good news story. Even as NIH continues to run into strong headwinds on CIO-SP4, I think there are just a new batch of protests filed last week. GSA has been able to move new contract programs out the door and right behind Polaris and Oasis Plus, Alliant 3 itself is on schedule. There’s a however, and you alluded to that, Tom. The however, is well,  if you’re looking at these contracts, that’s great. But the assisted acquisition service is part of GSA that manages many larger scale procurements on behalf of other government agencies. The lateness of appropriations is really going to have an impact on the work that they do. Typically, the assisted acquisition service offices, and there are several of them under the larger GSA umbrella, and there’s also assisted acquisition groups in HHS and the Department of Interior. Typically, they like to take projects up until late spring or early summer of a fiscal year and say, ok, that’s it, we’ve got our cart is full. We’ve got plenty of things that we need to work on to get awarded and committed by the end of the fiscal year. Well, that only works if customer agencies actually have their money and know what they can spend it on by that time. And this year, I’m looking at what’s going to happen in like, well, that’s probably really not going to be the case. So it’s going to push those assisted acquisition service operations into a significantly pinched timeline, reduced acquisition, lead times, a lot of work to be done in a very short period of time. I’m not sure that they’re going to be able to set a cutoff date, depending on what time frame Congress actually implements the appropriations measures. The earlier the better, but it may not be for a while. So I think this is going to definitely disrupt normal acquisition, even though you might have some new contract vehicles to use.

Tom Temin And if you are just making task orders, something that doesn’t need assisted acquisition, you’re just an agency buying stuff. Can you use the new versions Oasis two, for example, with continuing resolution money? In other words, your program isn’t new, but the vehicle you’re buying from is new or the contract award is new.

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Larry Allen Certainly you can use Oasis Plus once the awardees have an authority to operate, that program’s open for business. My understanding is that there is already some acquisition steps being taken. For small business acquisitions, those were the first wave of awards made under Oasis Plus. So it looks like work’s proceeding there. I would expect the same thing to be the case for Polaris. A lot of pent up demand. We’ve been waiting for Polaris for a long time. Awards should be made this week or next. Hopefully this week. Next week. Holiday week. So you want a new contract under your Christmas tree so you can get some work done in the new year. Once you get that authority to operate, then you’re okay to do business under that, regardless of the type of money that the customer has, so long as it conforms to the general use of that piece of work.

Tom Temin We’re speaking with Larry Allen. He’s president of Allen Federal Business Partners. And here’s another existential question. Should the new administration in January order agency personnel back to their offices, those that had an office or a cubicle 100% of the time say, I wonder what that will do to the acquisition of goods and services required to clean out the cobwebs, sweep up the dead spider plants and otherwise regenerate office activity.

Larry Allen Well, whether or not this administration, the incoming administration, Tom, has certainly signaled that it is their intent to move federal workers back into federal office buildings and wholesale telework, the telework that was brought about during the pandemic. So I think we can expect to see more people in an office. There probably isn’t going to be enough office space to put people in all the time. But generally speaking, are we going to see office buildings? If you listen to what the incoming administration is saying, then I would have to say, yes, you will see that. And what that means is increased opportunities for contractors, everything from janitorial, sanitation supply and service companies to office supply companies. I talked to a lot of companies over the pandemic that sell toner and office supplies, and they just saw their business, their federal business plummet. And I’m sure they would be eager to have the opportunity to tune up those machines, upgrade the capabilities and take care of the workforce that’s now back in the office.

Tom Temin And in the meantime, the contours of the Defense Authorization Act, which we could have maybe by the end of the week, looks like they’re going to get there by the end of the calendar year, as they traditionally do. But there’s a lot contractors need to pay attention to, as do agency buyers, with respect to Chinese related companies, Huawei, semiconductors, all of that.

Larry Allen That’s right. If you look at the Section 800 title of the defense bill, Tom, and that’s always the acquisition title. Some years there’s a little, some years there’s a lot. This year there happens to be a lot.

Tom Temin There’s a lot.

Larry Allen Under that title. And while there may not be any real one or two earth shattering things, electively the provisions are going to have a fundamental impact on how acquisitions take place moving forward. And you hit on a couple of them right up front. Significant restrictions on doing business hiring lobbying firms that also lobby on behalf of companies with ties to the Chinese military. So now you’ve got to vet your government affairs team to find out, do they have an organizational conflict of interest? There’s a provision in there that talks about doing business with Chinese nationals or people who are subject to Chinese laws and governance. So you’ve got to start to think about who you’re talking to and what the tenor of that conversation is. If there are Chinese national. And then of course, one of Congress’ favorite places to go for restrictions is Huawei. There are restrictions in this bill on using Huawei made semiconductors. If you look at those specific things and then you take up maybe a half a step back and look at other provisions in the defense bill that speak to domestic secure supply chains, increased cyber safeguards, you begin to see a common thread there. This is a government that still remains very serious and very much on guard about hacking in from people who may do us harm, from protecting us from bad actors, and ensuring that those suppliers that we’re doing business with as a government understand what their security requirements are, even if they’re selling something that may not automatically be associated with national security.

Tom Temin Right. So in general, then just getting back to the bigger picture of Title 800 series, Title eight of the NDAA, there’s a lot in there that contractors ought to read. And it’s hard going because sometimes the intent of a change is not really evident in the language of the bill. And so get your attorney, get your procurement consultant to ask, what are they really saying here?

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Larry Allen Well, that’s exactly right. If you read through the bill, there’s a lot of put a period here at the end of sub paragraph A, create a new sub paragraph B, and then put a comma, replace it with the semicolon and you don’t really understand what all that means at the end. So it is important to have somebody who can translate that language into English. Ironically, Tom, one of the provisions in the defense bill in the 800 title is a provision that would require DoD to issue plain language solicitations for small businesses, even though reading that part of the law may itself not be entirely in plain English. But there are also some provisions in there on the intelligence community, specifically about whistleblower protections in the intelligence community. So if your company is doing business in that sector, probably important for you to understand what those changes are. The general thrust of them is to protect people who will be whistleblowing in an intelligence community setting. So you want to know what that is. You really have to make sure that you are keeping your own house in order rather than waiting for somebody to come in and put it in order for you. That’s more expensive. It’s more time consuming, and it’s best if you just take the initiative yourself.

Tom Temin Yes. What do they say? The best thing about compliance is prevention.

Larry Allen That’s exactly right. I’m a big believer in that.

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