Memorandum from the Office of the Under Secretary of Defense

SUBJECT: Class Deviation – Limitation on Subcontracting for Small Business

Effective immediately, contracting officers shall follow the procedures provided in this class deviation when issuing solicitations and awarding contracts or rask or delivery orders under FAR part 19 to –

  • Small business concerns;
  • 8(a) Program participants;
  • Historically Underutilized Business Zone (HUBZone) small business concerns;
  • Service- disabled veteran-owned small business (SDVOSB) concerns;
  • Economically disadvantaged women-owned small business (EDWOSB) concerns; and
  • Women-owned small business (WOSB) concerns eligible under the WOSB Program.

The following procedures under the attached deviation clauses implement revisions made by the Small Business Administration to its regulation. These revisions changed and standardized the limitations on subcontracting and the nonmanufacturer rule with which small businesses must comply under Government contracts awarded pursuant to the set-aside or sole source authorities of the Small Business Act. This class deviation updates the limitations on subcontracting and the nonmanufacturer rule for all small businesses in the clauses relating to set-asides and sole source awards under FAR part 19.

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GSA makes final decision to sunset the long standing 72A Reporting System

GSA will sunset a long standing legacy system supporting the MAS Sales and IFF Remittance program and replace it with a more modern and efficient system.

The 72A Reporting System is scheduled to be shutdown during calendar year 2019. It will be replaced by the FAS Sales Reporting Portal (SRP), allowing GSA to streamline its sales reporting processes under one robust and modern system.

The goal of this transition is to provide a single reporting system for all contractors to use for reporting sales and remitting IFF. GSA’s overall IT modernization efforts include improving its IT enterprise by building and maintaining a more modern and secure architecture for its IT systems. This transition not only supports GSA’s modernization effort, but it streamlines the overall process of reporting sales and remitting the IFF, making it more efficient for GSA and its industry partners. The FAS Sales Reporting Portal (SRP) currently houses all the Transactional Data Repository (TDR) contracts and all new (as of July 2018) quarterly reporting MAS contractors. This continued effort will complete the transition of over 14,000 current contracts into the FAS SRP to allow for the sunsetting of 72A.

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Report to Congress Fiscal Year 2017 Annual Industries Capabilities

Office of the Under Secretary of Defense
for Acquisition and Sustainment
Office of the Deputy Assistant Secretary of Defense
for Manufacturing and Industrial Base Policy
March 2018

NDIA Top Line Summary of the 2018 Defense Industrial Base Study

The Defense Department has just released a study on the health and resiliency of the defense industrial base. As directed in Executive Order 13806, signed July of 2017, the report directed the Secretary of Defense to conduct a
government-wide examination of risks, impacts and proposed recommendations to ensure a healthy manufacturing
and industrial base.

5 critical mistakes small business contractors should avoid

Ready to jump into the $450 billion government contracting space? Don’t make these key mistakes.

It’s no secret that the U.S. government is one of the largest buyers and sellers of goods and services in the world, leading to tremendous opportunity for companies that earn federal contracts. If you are a small business or startup you are in luck as the government sets aside contract requirements in favor of small and socio-economic enterprises. For example, in 2017 the government awarded 24 percent of federal contract dollars to small businesses totaling $105.7 billion.

With the right amount of planning, preparation and effective networking, small businesses can thrive in the federal contracting space, but there are some major mistakes or red flags to avoid.

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From the Daily Reporter – Milwaukee ordinance to give bidding edge to ‘socially responsible’ contractors

A newly proposed ordinance in Milwaukee would give a bidding edge to city contractors who hire felons, help workers earn high school diplomas, or provide other “socially responsible” employee incentives.

The proposal, introduced by Milwaukee Alderwoman Milele Coggs, would award contractors additional points in the city’s bid-scoring system if they took three or more actions to reduce barriers to employment. Coggs said she decided to put the ordinance forward after meeting a contractor who had helped his workers get drivers licenses, pay legal fees and surmount other difficulties.

The new legislation is aimed at rewarding such companies and encouraging others to do more for their employees, Coggs said.

“You think about what can we do as policy makers to attempt to get others to be more socially responsible in what they do,” she said during a committee meeting on Wednesday. “So this legislation is just one small piece of Milwaukee leading the way to encourage contractors who work with the city of Milwaukee — who we spend taxpayer dollars with — to make the barriers to employment a little less for groups of people.”

Companies that adopt at least three policies or practices from a list of more than a dozen identified in the ordinance could get a slight edge when trying to win public contracts. Specifically, they’d get a 5 percent boost in the city’s bid-scoring system. But they could only get that advantage if their bid were within $25,000 of the lowest offer.

And there would be other obligations.

Contractors would also have to sign a notarized affidavit stating that they provide paid sick leave or other benefits to their workers, according to Rhonda Kelsey, Milwaukee purchasing director. Companies also could be required to hand their employee handbooks over to city officials, who could then use that information to verify that the new ordinance’s requirements are being met. The city spent $84.3 million in 2017 on contracts with independent companies and $104.3 million in 2016.

Here are some of the steps employers could take to qualify for the city’s socially-responsible contractor ordinance:

  • Hire people with felony convictions
  • Help employees earn high school diplomas
  • Provide internships, job shadowing, on-the-job training or similar opportunities
  • Help employees obtain instruction and training in math, construction and budgeting
  • Help employees obtain driver’s licenses, transportation vouchers, work clothes and safety gear, legal aid, career training, school supplies and other benefits
  • Provide breast-feeding centers for employees who are nursing children.
  • Provide a minimum of 120 hours of paid sick leave or a minimum of 5 paid sick days.

The proposed ordinance comes after the city tweaked its contractor rules in a way meant to ban offensive language or conduct on public job sites. Those rules were a direct response to images posted on social media showing employees of the contractor American Sewer Services, of Rubicon, carrying guns at a city job site. A subsequent photograph showed an American Sewer Services employee’s cooler decorated with a confederate flag sticker and a Klu Klux Klan sticker.

Milwaukee’s socially-responsible-bidder ordinance was also sponsored by Aldermen Russell Stamper II, Khalif Rainey, Chantia Lewis, José Pérez, Robert Bauman, Ashanti Hamilton and Cavalier “Chevy” Johnson. It drew support from the YWCA and 9to5 National Association of Working Women.

“When job quality is low, at risk communities are unable to be stable providers,” Astar Herndon, 9to5’s state director, said. “The socially responsible ordinance can help us move closer to that standard.”

‘Unprecedented’ Government Spending Spree Picks Up Speed

The spending spree is the product of the omnibus budget agreement signed six months late in March coupled with funding increases of $80 billion for defense and $63 billion for civilian agencies. The shortened time frame left procurement officials scrambling to find ways to spend the money.

Through August, defense and civilian agencies obligated some $300 billion in contracts. But to spend all the money appropriated to them by Congress, they may have to obligate well over $200 billion more in the final quarter of fiscal 2018, which ends in two weeks.

“It is not impossible for this to happen, but it is unprecedented for that high of a percentage to be obligated to contracts for a fiscal quarter,” David Berteau, president of the Professional Services Council, told Nextgov. “You’d have to spend almost 50 percent of the yearly total in three months.”

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Submission for OMB Review; Notarized Document Submittal for System for Award Management Registration


Office of Acquisition Policy, General Services Administration (GSA).


Notice of request for comments regarding an extension to an existing OMB clearance.


Under the provisions of the Paperwork Reduction Act, the Regulatory Secretariat Division will be submitting to the Office of Management and Budget (OMB) a request to review and approve an existing OMB clearance regarding a notarized document submittal for System for Award Management (SAM) Registration.


Submit comments on or before October 9, 2018.

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