May 26, 2013

NAGC Article on SAM.GOV Problems

By Simon Brody
Wednesday, September 12th, 2012

Contractors will not yet be required to register online to sell goods and services to the Defense Department. Although required by the Federal Acquisition Regulation, technical problems with the government’s newly launched SAM procurement system have delayed implementation.

A recent memo from Richard Ginman, director of defense procurement and acquisition policy, pointed to issues with the System for Award Management in announcing that contractors would not have to adhere to the registration requirement before bidding on government work.

“Since implantation, SAM has experienced performance issues that have affected the timely processing of awards,” Ginman wrote. “GSA has taken aggressive action to resolve these issues promptly. This deviation provides a brief period of time for achieving resolution of the remaining issues, and will remain in effect only until these actions are complete.”

According to the memo, which was obtained by Washington Business Journal, contractors are required to be registered in SAM prior to submitting invoices, but not prior to award; also, contracting officers are not required to check SAM to ensure registration prior to an award. They may require prospective contractors to attach copies of other annual representations and certifications in lieu of online access to that documentation.

SAM was officially activated July 29 after numerous delays, consolidating the Central Contractor Registration, which maintains company data; the Excluded Parties List System, which tracks companies and people suspended or debarred from doing business with federal government; the Federal Agency Registration, used to collect standard data on federal agency buyers and sellers; and the Online Representations and Certifications Application, where contractors essentially confirm that they are qualified to do business with government.

Since then, contractors have complained about the system being cumbersome, bugging and inflexible. GSA have ordered SAM developer IBM Corp. to develop a plan of action to improve SAM.

Strategies and Themes for Proposals

One of the popular topics in proposal development is the idea of win strategies and themes.  If you can just distill down your proposal to a strategy or a set of themes you can get your message across and win.  The problem with this is there is no way anyone can know whether a strategy is a winning strategy or a theme is a winning theme before the evaluation process is completed.  So what is a company or organization to do to win?

The answer is pretty simple.  One must develop a solid strategy and communicate it through straight forward themes using all the knowledge your organization possesses about what would make your customer successful.  A theme is a bullet point or quick idea that helps someone understand what you writing about, for example, “Strategies need to come from the proposer” or “A theme is a single point in regards to your strategy.”  The strategy is your solution; the way you go about satisfying the customers wants, like, “Develop your strategy and themes and then allow them to evolve into a winning strategy and concise themes.”.

You should not worry about “winning” until you have a strategy that can be communicated through themes.  Know how to solve the customer’s problem and communicate concisely.  Then the evolutionary process begins with you looking at it from different perspectives, asking new questions, and learning more and more about what is important and what is not.

Strategies and themes mature as you learn more about your customer, the market, and your organization’s capabilities.  Everyone has been in the situation where a request for proposal hits the street and it is looking for an exciting solution to a cool problem.  You know in your gut you can do it and that the customer will be delighted with your ideas.  You propose and find out you did not win.  Through the debriefing process or the grapevine you learn that your ideas were innovative but your technical approach was lacking, or your personnel were not viewed as up to the task.  You tell yourself that next time you will change your strategy to reflect the desired technical approach and highlight the capabilities of your personnel more as an important theme.   Over time as you compete in the marketplace your strategy becomes refined and your themes become clearer.  Interest begins to build in your proposals.  In the end, you are satisfying the needs of the customers and winning contracts.

Accounting Flow on a Federal Contract

Similar to how the technical work on a government contract has a particular flow of proposal to final deliverable the accounting also has a flow that has a beginning and an end.  Although government accounting impacts the entire organization we are focusing just on the accounting that comes about from winning and executing a government contract.

The cost proposal is the start of the government accounting process.  The cost proposal lays out your expected direct and indirect costs related to the proposed effort.  The government will use it as a basis for a Billing Rate Audit, which will establish the percentage that can be added to direct costs related to execution of the contract to cover indirect costs.

For example, a lumber yard uses a $15,000 truck to make deliveries.  The lumber yard delivered $1,000,000 worth of lumber with the truck over it’s lifetime.  The indirect expense on the lumber would be $15,000 divided by $1,000,000 or 1.5%.

Now let’s say you proposed to deliver $10,000 worth of lumber for the government.  The cost proposal would be:

Cost of Lumber $10,000
1.5% Indirect Cost $150
Total $10,150

The government will conduct a Billing Rate Audit to confirm/establish your indirect billing rate of 1.5% for this overly simplified example.

In addition to the Billing Rate Audit the government will conduct an Accounting Systems Audit to ensure your accounting system is capable of tracking and separating costs among different projects in order to insure that the government pays the proper amount.

At this point, in the contract life cycle the government and you have established the proper rate to reimburse indirect expenses and that the accounting system that you will be using is acceptable to the government. Now it is time to execute on the contract which brings us to the phase of Incurred Costs.

The Incurred Cost phase is where you as the contractor track your indirect costs and then spread them over all of the work accomplished by the firm over a set period of time, usually one year. You will submit this information to the government and the government will audit it to determine where your actual indirect cost rate is compared to your Billing Rate.

After successfully completing the project, the government and you will wrap things up with Final Rate Negotiations and a Final Invoice. Which will lead to the close out of the contract and the end of the contract accounting life cycle.

In summary, the government contract will go through the following accounting life cycle:

  1. Cost Proposal
  2. Billing Rate Audit
  3. Accounting System Audit
  4. Incurred Cost Submittal
  5. Incurred Cost Audit
  6. Final Rate Negotiations
  7. Final Invoice