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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.

Carrie Jokiel of ChemTrack

Woman-Owned Small Business Spotlight: ChemTrack

Welcome to the second edition of our woman-owned small business spotlight series. This edition highlights ChemTrack, an environmental engineering, remediation services, and construction company. The company’s President, Carrie Jokiel, shares her story and advice for other woman-owned small businesses.

Can you provide a brief overview of what ChemTrack does?

ChemTrack is an 8(a) Alaskan Woman-Owned Small Business, specializing in environmental engineering, remediation services, and construction. We combine geological, chemical, hydrological, and engineering expertise with a broad understanding of regulatory and risk frameworks to solve environmental assessment and regulatory compliance problems for our clients. ChemTrack tailors innovative methods and concepts to individual problems and provides environmental solutions, especially as they apply to arctic and subarctic conditions in Alaska.

What inspired you to start ChemTrack?

I’m a born and raised Alaskan woman and second-generation “ChemTrackian.” My mother grew up in bush Alaska, our remote areas, as my grandparents were teachers in the villages. My dad emigrated here from Germany to attend the University of Alaska Fairbanks back in the ‘60s. He fell in love with my mom and the spirit of Alaska. Being raised with that same spirit led me to becoming partners with my father and eventually becoming majority owner. We both share the entrepreneurial spirit that comes from the beauty and opportunities this great State has to offer.

That combination of respect and entrepreneurship has created a workforce culture that truly enjoys what we do to prevent negative environmental impacts, restore our remote areas to their original pristine conditions, and work together with our clients that share our passion for the State of Alaska.

What is your proudest moment for ChemTrack?

This summer season is already kicking off to be my proudest moment. I feel like we have arrived.  We have worked incredibly hard to be prepared to have a good season and I see the fruit of that labor happening. We were coming off a tough, stressful season last year, and the resilience my team has shown along with the can-do spirit, has been incredible to witness.

What is the biggest challenge you have overcome with ChemTrack?

We had a project go sideways two seasons ago that had a ripple effect into last year’s season as well.  It stressed our company at every level; it pulled my focus away from our strategic plan into survival mode; it affected the crew involved on the project, from the project manager to each laborer.  Amazingly, it also bonded us together. We were all in the trenches together, backs against a wall, and we survived. I wouldn’t wish tough days on any business owner, but the grit my crew showed and what we learned from our challenge has made us a much better company and now, we are poised to thrive.

What advice would you give to other women entrepreneurs?

Listen to the nudges you feel when leading. Realize you are a master of your trade and how you lead may seem unique to the mainstream we are often surrounded by. Know that your intuitiveness matters, and is at its core, how YOU run your company. Basically, you know what you’re doing – keep crushin’ it.

Do you have any suggestions on resources that women-owned small businesses should use?

To keep up on what our government is doing to help women-owned small businesses, get involved in Women Impacting Public Policy (WIPP).  If starting out, get to know your PTAC office.  If a federal contractor, get to know your local SBA office personnel.  If you’re a federal contractor and can budget it, use a service like FEDMINE to track and monitor RFPs, competitors, and contracts. Good luck!

To learn more about ChemTrack, visit their website at http://chemtrack.net/.

JetCo Federal President to Speak about Contracting Compliance

JetCo Federal’s President, Sue Tellier, will be speaking about government contracting compliance at a Women Impacting Public Policy (WIPP) Education Platform webinar on Tuesday, June 30 at 2 PM ET.

The webinar, titled “Compliance Begins Before the Win”, will outline the structure of compliance JetCo Federal has built for federal contracting, which has allowed us to diversify with confidence in a manner that decreases risk. Effective compliance begins before the win, and small size status is not an obstacle to building a culture of compliance.

The webinar is free to WIPP members and is $25 for non-members. You can register for the webinar on the WIPP website.

 

CMMC and the Importance of Cybersecurity

In mid-2020, the Department of Defense will begin enforcing provisions of the Cybersecurity Maturity Model Certification (CMMC) for all contractors, augmenting the NIST SP 800-171 recommendations that have been standard for governing protected information since the early 2000s. This change is already having major impacts on organizations working toward compliance. When the requirements begin appearing on contracts in June, it is expected that there will be immediate effects for the industries and companies that rely on government sales, even indirectly.

Not familiar with CMMC? Here’s a primer:

CMMC Certification Logo

What is CMMC?

The Cybersecurity Maturity Model Certification (CMMC) is designed to combine best practices and standards from across the security industry, creating a uniform policy that reduces the risk of threats to Federal Contract Information (FCI) and Controlled Unclassified Information (CUI) – data that is protected from public disclosure but not necessarily access-restricted by law or regulation.

How will CMMC be implemented?

The implementation of CMMC includes standards for physical system access, operations and maintenance, documentation, and digital system access. A key difference between CMMC and earlier frameworks is the certification requirement: companies can no longer self-certify their compliance. An independent 3rd party must now audit the implementation. Additionally, subcontractors are also required to adhere to CMMC, even if they do not handle CUI directly.

Luckily for companies trying to navigate the often-muddy waters of government contracts, CMMC uses a tiered system. Not all companies need to apply the strictest standard, so there are five levels of compliance, ranging from “Basic Cyber Hygiene” to “Advanced/Progressive”.

The basic levels are designed to result in a uniform minimum level of protection, without being cost-prohibitive for most organizations. In some cases, the implementation may be eligible for reimbursement by the Department of Defense. Check for the CMMC certification required to bid in sections L & M of government RFPs.

Why cybersecurity?

According to the Council of Economic Advisors, it’s estimated that malicious cyber activity cost the U.S. economy between $57 billion and $109 billion in 2016. Cybersecurity is not only important for keeping federal contract information and data secure, but it’s also important for companies wanting to keep their own confidential data secure.

JetCo Federal has achieved Level 1 CMMC compliance and is working with our partners to become Level 2 certified. We have always believed in data security as a core component of managing complexity successfully, and that strong access and documentation protocols protect us as well as our customers. For our commercial clients, suppliers, and partners, this means that when we transmit, store, or manage their confidential data, it’s subject to those same restrictions and protection. For some organizations, the extra compliance might be frustrating, for JetCo Federal, it’s just another part of how we re-win our business every day.