Category Archives: FAR Regulations

UPDATED 9.12.12! Trying to Update CCR or ORCA? Forget About It!

UPDATE 9.12.12
Per a Department of Defense memo dated 8.21.12, a Class Deviation has been granted exempting contractors and contracting officers from specific CCR and ORCA [now SAM] requirements until further notice and resolution of SAM performance issues. Click here to read the full DoD memo which provides guidance on when CCR (SAM) registration is not required, when CCR (SAM) registration will not be checked, and when an expired ORCA (SAM) record will be acceptable. Also of note, GSA has re­established the EPLS website (www.epls.gov) to provide contracting officers the ability to ensure a prospective contractor is not actively excluded from procurement actions.

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ORIGINAL POST 8.21.12

If you have tried to update your company’s CCR or ORCA information lately, you’re probably ready to pull your hair out. The problem is SAM (System for Award Management) is all hosed up. SAM intended to consolidate eight acquisition databases, including the Central Contractor Registration (CCR), the Online Representations & Certifications Application (ORCA), the Past Performance Information Retrieval System (PPIRS) and five others launched July 30th, then went offline for maintenance until August 6th. SAM went back up Aug. 7, but with continued slow performance and other issues.

Prodded by complaints from the Chief Acquisition Officer’s Council, on August 7th GSA issued IBM an official Notice of Concern telling the company to develop a plan of action and milestones for how they will make SAM work more smoothly

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Is “Bid to Win – Manage to Profit” Still a Viable Strategy?

It won’t be if a recent Court of Appeals ruling is any indication.  The 9th Circuit Court of Appeals recently held that  a contractor could conceivably be subject to the False Claims Act for invoices submitted under a cost reimbursement contract that was based on a proposal that was “fraudulently underbid.”   Significantly, the case was brought by a qui tam relator, an ex-employee of the contractor who had personal knowledge of how the estimate was developed.  Consequently, this could happen to any contractor, even if the government was not originally involved. 

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NCMA World Congress was a Smashing Success!

Aronson had the privilege of attending the National Contract Management Association World Congress held this year in Boston.  Over 2,000 contracting professionals from both government and industry participated in the Congress which spanned July 29th through August 1st.  The theme was Efficiency, Efficiency & Transparency, all important subjects in the new more austere and ever more regulated world of government contracting.  The speakers, Dov Seidman, author of “HOW: Why How We Do Anything Means

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System for Award Management (SAM) is Active! Now What?

Time to update your computer bookmarks! The System for Award Management (SAM) is active. As of July 30, 2012, Central Contractor Registration (CCR), Online Representations and Certifications Application (ORCA), Federal Agency Registration (FedReg), and the Excluded Parties List System (EPLS) websites all  re-direct to the SAM website at: www.sam.gov. CCR/FedReg, ORCA, and EPLS systems are no longer accepting new data. So how can you access SAM and where’s all your data located?

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Small Business Prime & Subcontractors to be Paid Faster Under New Rules

Last September, the Office of Management and Budget (OMB)  issued Memorandum 11-32 “Accelerating Payments to Small Business … ”   Pursuant to this memorandum, all executive agencies were instructed, to the extent practicable, to make payments to small business prime contractors within 15 days of receipt of the invoice.  The administration is now taking a similar approach to accelerating payments to small business subcontractors. 

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