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VETS-4212 and Contracting Compliance

If you’re a prime government contractor, or even a subcontractor, the term VETS-4212 might be familiar to you. While it’s one of the many FAR clauses that can be in a solicitation, VETS-4212 acts as a good example when it comes to government contracting and compliance within the government sales process. Before we dive into the importance of compliance and communicating flowdown clauses, let’s first take a look at VETS-4212.

VETS-4212

VETS-4212 is an annual report that is required to be filed by the U.S. Department of Labor (DOL) Veterans’ Employment and Training Services, or VETS. The VETS-4212 annual submission form must be filed by all federal contractors and subcontractors who enter into a contract larger than $150,000 with any department or agency of the United States for the procurement of personal property and non-personal services (including construction).

The annual filing period for VETS-4212 is August 1 – September 30, and the form can be filed at the Department of Labor website or mailed in. Filing online is preferred by the DOL and also allows for batch filing if you need to file for multiple locations.

Contracting Compliance

Why bring up VETS-4212? VETS-4212 is a good example of a flowdown clause that must be communicated between prime contractors and subcontractors. As a prime contractor on many government solicitations, it’s extremely important at JetCo Federal that we take precautions in understanding what FAR clauses and regulations need to be realized by our suppliers.

This is why maintaining relationships and having open communication with our suppliers is core to our business. We candidly talk about payment terms, flowdown clauses, and expectations when we’re working with our suppliers to ensure compliance within the complex structure of government solicitations. This style of communication, in addition to our prompt payments, has cemented us as a priority customer for our suppliers.

The VETS-4212 annual submission is no exception and must be discussed anytime a solicitation lists FAR Clause 522.222-37 or is over the $150,000 threshold. This is why with every contract we enter into, we develop a contract compliance matrix to ensure all requirements are met and all reporting needs are noted and clearly communicated.

Contract compliance can be a time consuming and confusing aspect of any government opportunity. It’s important that compliance, specifically when it comes to flowdowns and subcontractors, is clearly communicated and approached efficiently so that suppliers can do what they do best while we handle the fine print of government solicitations.

Are you a highly qualified supplier interested in working as a subcontractor on a government solicitation? Contact us to learn more.

Reliability During Uncertain Times

Over the past few months, the COVID-19 pandemic has caused the government’s buying methods to shift significantly. Though the traditional buying process is still in place, the government has turned to quicker methods, such as single-sourced non-competed contracts, to help get resources to where they are needed. However, this buying method has its downfalls. The government is struggling to reliably secure critical supplies. Here’s an example.

FEMA and Unusable Testing Kits

In May of 2020, the Federal Emergency Management Agency (FEMA) awarded a $10.2 million contract to Fillakit LLC, a company that was formed just six days before the contract was awarded. They also had no previous experience working with the government. Fillakit was formed by an ex-telemarketer who has been accused of fraudulent practices over the past two decades. Due to the hasty contract award, Fillakit supplied testing kits to the government. Now, the government has millions of testing kits that are unusable due to unsanitary manufacturing conditions.

Fillakit isn’t the only company that has been awarded a contract without having worked with the government before. A recent Government Executive article states that “federal agencies hastily awarded more than $2 billion in COVID-19 contracts to vendors who had no prior federal deals.” They also stated that “the federal government has committed more than $16 billion to more than 4,000 contractors in its attempt to address the spread of the novel coronavirus. More than 1,800 of those deals were given without competitive bidding.”

As traditional buying methods shift during COVID-19, it’s more important, now than ever, to ensure the government has access to and is working with highly qualified government contractors. Vetting processes need to stay in place to allow the government to reliably secure the critical supplies they need. It all comes back to working with a government contractor who is qualified. So, how do you identify a qualified government contractor?

How to Identify a Qualified Government Contractor

One quality of a highly qualified government contractor is strong past performance. Companies that show they have done similar work to the contract, and in a similar capacity, have the experience and expertise to meet the needs of a contract.

Another quality of a qualified government contractor is compliance processes. If a company is not compliant with their current contracts, the likely won’t be compliant with the upcoming contract. Make sure the contractor has compliance processes in place before awarding them the contract

These are just a few qualities of a qualified government contractor. Though COVID-19 has shifted the government’s buying methods, now more than ever, the government needs to work with highly qualified companies that bring trust and reliability to the table.

JetCo Federal is a supply chain management and warehouse supply company with a successful past performance managing diverse products for complex contracts. Compliance, trust, and efficiency are ingrained into our company, and we’re ready to embrace the challenges that come our way.

Quality Products, Quality Systems

Quality must be demonstrated – not merely claimed – to be legitimate. It can be expensive. It requires deep commitment from leadership. It means accountability for every business unit.

Pursuing and maintaining International Organization for Standardization (ISO) registration is the demonstration of these values as operationalized and integrated throughout an organization. ISO registration recognizes the standards that go beyond a selling point: they’re real, they’re tested, and they’re a long-term strategic investment.

Interestingly, effective quality systems help avoid production and supply chain failures. While JetCo Federal initially decided to pursue ISO 9001:2015 registration for credibility, we found peace in the risk reduction and enhanced productivity it brought.

Here are a few observations for other small businesses contemplating their quality systems:

  1. The “operationalized and integrated” aspect of quality management is where quality pays off. When quality is a department, the system fails. When quality is a culture, it thrives and becomes viral. We have quality checks built into sales, compliance, fulfillment, and transportation.
  2. Yes, I said sales. Without an eye for quality in the initial discussions of potential new projects, a sales win can result in an operational failure – one that cuts into profits and damages company credibility.
  3. Like other small businesses, we’ve found process efficiencies and enhanced productivity through our quality management system. It allowed us to clearly articulate our requirements for software to support operations capabilities. We have documented systems and work instructions, leading us to know exactly where we wanted alerts for human intervention.

Our quality management system is demonstrated, operationalized, and integrated. We value our customers and uphold our commitment to supplying the highest quality products both now and in the future.