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Federal Reseller Liability Under the US Trade Agreements Act (TAA)

There was a significant development in TAA compliance for federal resellers, when a recent decision by the U.S. Court of Appeals for the District of Columbia Circuit dismissed a False Claims Act suit filed against contractors for reselling Chinese-made (non-TAA compliance) technology products to the U.S. government.   In case number 13-7049, Govplace, Inc. and Government Acquisitions Inc. were accused of engaging in fraudulent behavior because they relied on their product supplier’s (Ingram Micro, Inc.) certification, which stated that the technology products supplied were from a TAA compliant country.

Prosecutors argued that it is a contractor’s responsibility to not simply rely on the TAA compliant certification, but also to conduct their own investigation to affirm the country of origin for every supplied product.  However, the case was dismissed after the court decided that there was no reason to doubt the legitimacy of the supplier’s certifications, and that trusting them…

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New SAM.GOV Rule

If you’ve updated your SAM.gov registration recently, you may have seen a new ownership page.  A final rule recently amended the Federal Acquisition Regulations to require all SAM registrants, if owned by another entity, to identify that entity by name, CAGE code, and type of ownership.  This rule will provide government insight into 1) Federal spending patterns across corporations, 2) Traceability in tracking performance issues across corporations, 3) Contractor personnel outside the United States, and 4) Supply chain traceability and integrity efforts.  As the final rule noted, “Increased transparency and accuracy of procurement data broaden the Government's ability to implement fraud detection technologies restricting opportunities for mitigating occurrences of fraud, waste, and abuse of taxpayer dollars.”

Ownership is defined as a “Highest-level Owner” and “Immediate Owner”.  Ownership is defined as an Entity having ownership or control.  And an “Entity” is defined as an…

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How to Market to the Government – B2G Marketing

Many GSA Schedule Holders and prospective government contractors believe that selling to the government is a simple task. Hold on there - selling to the US government, the largest buyer in the world, is no easy task. Organizations need to market toward the government through an extensive and developed strategy. This requires organizations to do their homework about Business to Government (B2G) marketing.

Step 1: Chasing and replying to Request for Proposals (RFPs) and Request for Quotes (RFQs) is a waste of time.

Studies have shown that on average only 4% of organizations that blindly bid on RFQs/RFPs actually win a piece of the business. The bad news is that with such a low chance of winning, many organizations are still spending valuable time and boatloads of money on responding blindly to RFPs.Instead of wasting time on responding these blind RFPs, organizations need to seep into the core of their organization and find their most attractive marketing features. Once they have…

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Interview with Brian Miller at GSA’s Office of the Inspector General

disclosureIn a recent interview with the General Services Administration (GSA) Inspector General (IG), Brian Miller, several questions in regards to the subject of voluntary disclosures leading to suspension or debarment were asked.

One of Miller’s answers came as something unexpected as a GSA IG. Miller emphasized that the IG does not refer GSA contractors who make disclosures for debarment. He values the relationship that GSA has with contractors and feels that there is no reason to refer suspension or debarment to a company, who comes in and discloses their conduct. This is because he believes that, “they’re doing the right thing in coming in to us.” It seems that if you act in good faith as a government contractor and disclose to the GSA OIG your conduct, you will remain, as Miller States a “partner” with the Federal Government.

Winvale has worked with several clients recently on assisting with them with voluntary disclosures. In addition, our team agrees with Miller’s encouragement in…

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Great IT Assets Come with Great Responsibilities

Protecting IT AssetsGrowing viruses and continuous cyber hacks have government agencies and corporations concerned about the safety of their IT assets. Most organizations fail to realize that simple steps taken toward protecting IT assets are essential and will save them tons of costs, and seize the possibility of an attempted hack. 

The Bad News

Intrusions in the IT sector for organizations are impossible to ignore.  An “FBI” virus was recently reported from an Arizona news station showing that all levels of business and government are affected by cyber-attacks due to poor IT asset management. Much like the responsibility of keeping people safe that superheroes like Spiderman and Batman take on, the IT department must keep IT assets safe. The more complex an organization, the greater the burden and with that burden, a greater responsibility arises for IT to keep their assets safe.

The Good News

The burdens of these “heroic” responsibilities in IT asset management (ITAM) are attainable and there is…

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Spring Cleaning For Your Service Desk

ITSM – Service Desk Ticket System Field and Categorization Simplification 

As anyone who owns a home or has a garage knows, we tend to collect stuff over time that we no longer need (or maybe never really needed) and then keep those items stored in places where they are in the way, or where they just simply look out of place. Maybe those items are now keeping us from seeing or even getting to the useful stuff that we are actually looking for. Well, this might also be the same problem that some of you are experiencing with those seldom or never used fields and selections in your Service Desk or Help Desk online ticketing systems. IT specialists would identify these as categorization selections like “PDA”, “dongle”, and “floppy drive”, or selections of application systems that they probably retired three years ago. These applications may even have fields that that no one uses anymore because they are not sure what those fields were intended for. 

Spring has Sprung! 

At this point,…

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