In January, GSA decided it will invoke the Continuity of Service (CoS) clauses for expiring enterprise network and telecommunications contracts. This will allow agencies an additional year to either complete their transition to Enterprise Infrastructure Solutions (EIS) or find another solution to prevent interruption of services.
Transition has been slow for many federal agencies. As of June 30, 2022, only 94 percent of the planned task orders for transition have been awarded. Also, 5.3 million of the nine million legacy services governmentwide are still in use. These services range from telephone lines to high bandwidth secure internet access.
We urge agencies to push toward completing 100 percent disconnection of services by September 30, 2022 and assess their risk of not completing transition by May 30, 2023. Those who need more time to transition must sign a Memorandum of Understanding (MOU) to be authorized to use the CoS period from June 1, 2023 to May 31, 2024.
Sign the MOU by September 30th
If an agency does not sign the MOU by September 30, 2022, GSA will remove the agency from the Networks Authorized User List (NAUL) for the expiring contracts. The contractors will begin the disconnect process as early as November 2022 and complete it no later than May 2023.
Agencies that want to take advantage of the CoS period can do so only under these conditions:
- Agencies must sign a Memorandum of Understanding (MOU) with GSA by September 30, 2022: GSA has sent a copy of the MOU to all potentially impacted agencies. The MOU must be signed by the agency head, or their designee with delegated authority. If an agency’s transition team has not received a copy of the MOU, please contact GSA at email@example.com.
- On May 31, 2024 (the end of the 12-month CoS period), any services remaining active on the expiring contracts will be disconnected, according to the terms and conditions of their respective contracts. Services cannot be reinstated on those contracts.
If an agency will not complete transition before the CoS period ends, the agency must:
- Identify the services that will be cut off when the CoS period ends;
- Develop a contingency plan to maintain operation of those services on another contractual arrangement; and
- Implement that contingency plan so when the contracts expire and the services are disconnected, the agency’s mission is not interrupted or otherwise negatively affected.
If your agency is mid-transition, weigh the pros and cons of signing the MOU and make a risk-based decision appropriate for your agency.
GSA remains available to help you assess your transition risk and understand your acquisition options. We are holding monthly EIS Transition Office Hours and monthly Interagency EIS Transition Meetings, both of which act as a forum for agencies to share best practices and lessons learned and ask transition-related questions. For an invitation to these open forums, please email firstname.lastname@example.org.
The legacy telecommunications contracts are expiring very soon. Do not delay in transitioning services and, if needed, signing the CoS MOU and conducting contingency planning.
GSA is and will continue to actively monitor agency progress toward stated EIS deadlines. If you need assistance, have additional data to share on the speed of your transition to EIS, or would like to meet with us, please contact your assigned GSA Solutions Broker.
For more information, visit gsa.gov/eistransition.
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