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Acquisition & Business Policy Spotlight

March 2024

Good Morning, ,

The function of the Professional Services Council's (PSC) Acquisition and Business Policy Council is to develop PSC’s policy positions and mobilize action and industry advocacy on major business and buying policy initiatives across the U.S. federal government.

 

This month's Spotlight reviews the council's work with Congress to raise additional General Services Administration awareness and recourse to alleviate perennial issues with its SAM.gov Unique Entity Identifier procedures, and also our comments to the FAR Council on better harmonization of suspension and debarment procedures between the FAR and Nonprocurement Common Rule (NCR).

 

PSC will early next week have a draft available for review regarding the FAR Council's Proposed Rule on Pay Equity and Transparency in Federal Contracting which we will be submitting on April 1, and we are keeping our eye on the Federal Highway Administration's Proposed Rule on Buy America Requirements for Manufactured Products, though are still considering whether we will submit comments by the due date of May 13.  

 

As always, I am readily available to provide any additional information, by phone or mail. Please advise if additional information is requested on any or all of these items.

 

At your service,

 

Sebastian

 

Sebastian Beau Herrick
Director, Procurement Policy
Professional Services Council

Quick Links

 

Congressman Gerry Connolly Letter-SAM.gov and UEI Issues | Procedures on Suspension and Debarment | Pay Equity and Transparency in Federal Contracting | Buy America Requirements for Manufactured Products | Mid-Size Company Working Group Meeting

 

PSC Advocacy Update

 

Congressman Gerry Connolly (D-VA-11) Letter on SAM.gov and UEI Issues
On Wednesday, March 5, 2024, Congressman Gerry Connolly (D-VA-11) submitted a letter to GSA Administrator Robin Carnahan making recommendations on additional supporting documents GSA should consider for entity validation and recommending reconsideration of the one CAGE Code per Unique Entity Identifier per address rule. The letter included language recommended by PSC members and Connolly constituents that would help GSA improve its transition to Unique Entity Identifiers from the previous Dun and Bradstreet numbers. The letter is available here. 

 

PSC Comments: Procedures for Suspension and Debarment

On March 11, 2024, PSC submitted comments on a FAR Council proposed rule to improve the consistency of suspense and debarment procedures for contracts and grants, cooperative agreements, etc. PSC comments focused mainly on removing from the FAR the immediate exclusionary effect of proposed debarment. You can read PSC's submission here. 

PSC Opportunities to Engage

 

FAR Council: Pay Equity and Transparency in Federal Contracting

On January 30, the FAR Council and Office of Federal Procurement Policy published a proposed rule on “PayEquity and Transparency in Federal Contracting.” It would prohibit contractors and subcontractors from seeking and considering information about job applicant compensation history, and require contractors and subcontractors to disclose the compensation to be offered in all advertisements for job openings related to contracts. PSC will submit comments on the due date of April 1, and will have a draft available for interested member review and line-in, line-out feedback early next week, the week of March 25. Please email me at herrick@pscouncil.org if you would like to see a copy of the draft. 

 

Buy America Requirements for Manufactured Products

On March 12, the Federal Highway Administration published a notice of proposed rulemaking that would discontinue its general waiver of Buy America requirements for manufactured products and in doing so require FHWA recipients to start applying Buy America requirements to manufactured products. The FHWA is also proposing standards for applying Buy America to manufactured products should the waiver be discontinued. PSC is considering submitting comments. Please send any input you may have to me at herrick@pscouncil.org for consideration. 

 

April 2 - Mid-Size Company Working Group Meeting

On Tuesday, April 2 at 10:00 am EST, PSC's Mid-Size Company Working Group will hold a meeting to discuss recent stakeholder and congressional interest in better business growth. Our meeting will set strategies and goals for PSC's mid-size advocacy agenda, as well as review the progress that has been made on behalf of this segment of business. If interested in joining the meeting, please take a moment to fill out our mid-size federal contractor survey, the anonymous results of which will be presented at the meeting. If new to the group, please take a moment to review PSC's Mid-Size Federal Contractor Issue Paper for an understanding of PSC's policy positions on the topic. You may register for the event here.