Last Chance: Signing Deadline Approaches for Expiring Telecom Contracts Continuity of Service MOU

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 eistcc.ta@gsa.gov.
  • 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.

GSA Resources

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 benjamin.todd@gsa.gov.

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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ICYMI: ITC Activating Continuity of Service for Telecom Contracts

In case you missed it, we are invoking the continuity of service (CoS) clause for these expiring enterprise network and telecommunications contracts: 

  • Networx
  • Local Service Contracts
  • Washington Interagency Telecommunications System (WITS) 3

This gives agencies the opportunity to sign on for an additional 12 months of service. During this time, agencies must either complete their transition to Enterprise Infrastructure Solutions or find another solution to prevent interruption of services. 

Invoking the CoS clause helps reduce the risks associated with not completing transition by the original May 31, 2023 deadline. It also provides more time for agencies to address challenges resulting from delayed task order awards, supply chain disruptions caused by the pandemic, and other important priorities.

The transition to EIS has significant governmentwide cybersecurity, mission, operational, and financial implications. Agencies that don’t move their services before the CoS period ends could face: 

  • Interruption of critical public services.
  • Increased cyber vulnerabilities.
  • Failure to carry out their missions.

More time to complete transition

GSA awarded EIS in 2017 to replace these expiring contracts, beginning a period of transition. Many federal agencies aren’t on track to complete their transition to EIS before the May 2023 expiration.

As of February 28, 2022, only 89% of the planned task orders for transition have been awarded. Also, 45% of the nine million services governmentwide (like telephone lines and high bandwidth secure internet access) are still in use. 

What this means for agencies

Agencies that want to take advantage of the CoS period can do so only if:

  • The agency signs a Memorandum of Understanding (MOU) with GSA by September 30, 2022
  • The MOU is signed by the agency head, or follows agency delegation of authority.
  • The designee is accountable for Chief Information Officer (CIO), Chief Acquisition Officer (CAO), and Chief Financial Officer (CFO) functions. 

At the end of the 12-month CoS period (May 31, 2024), any services remaining active on the expiring contracts will be disconnected according to the terms and conditions of their respective contracts. They cannot be reinstated on those contracts. This will occur at the contract level, not on the agencies’ task orders.

If an agency doesn’t transition before the exercised option or 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. 
  • Implement the contingency plan to ensure mission isn’t disrupted when the contracts expire and services are disconnected.

If an agency does not sign the MOU, GSA will remove the agency from the Networks Authorized User List (NAUL) for the expiring contracts in October 2022. Contractors will then begin the disconnect process as early as November 2022 and complete it no later than May 2023.

What this means for our industry partners

As agency transition rates increase, so will the demand on industry partners to implement task orders and execute disconnects quickly. 

We value our industry partners and will work closely together as we execute contractual actions over the next year. We’ll also look to our partners to continue supporting our agency customers as they

  • Expedite EIS orders.
  • Explore other options for maintaining service on another contractual arrangement.
  • Reconcile records for services that are being disconnected.

Next steps

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. We’re here to help you assess your transition risk and understand your acquisition options.

Agencies with services on the expiring contracts should expect a message from GSA in May 2022 including the MOU. If you need more information or would like to meet, please contact your assigned GSA Solutions Broker.

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Listening, Learning, Acting: Customer Needs Are Front and Center in FY21

The recent White House customer experience Executive Order holds government agencies accountable for “designing and delivering services with a focus on the actual experience of the people whom it is meant to serve.”

This philosophy of centering service around an individual customer’s experience is easy to comprehend but tough to execute. Our goal is to help agencies deliver on their missions to the public. To do that, we connect them with businesses offering approved, secure technology solutions that are customer-centric, cost effective, and compliant.

ITC was able to perform well in FY21 by listening closely to customers and taking action based on their needs. Whether working with agencies federal, state, local, or tribal, big or small, we consistently get asked the same questions:

  • Can you guide me through finding the solution I need and help me acquire it efficiently?
  • How can you save me money on the solution I need?
  • Can you ensure that the solutions I purchase are compliant with regulations and security directives?

In FY21, ITC provided a model for how government employees can thrive in remote work environments. We conducted a great deal of government business despite supply chain and other pandemic-related challenges, recording over $32 Billion of business volume. We improved CX in buying and selling technology and saved our customers time and money, modernized their networks, and secured their systems. We welcomed 315 new small and disadvantaged businesses onto the Multiple Award Schedule (MAS) in FY21. These efforts are ongoing, but have underpinned much federal government success during the pandemic.

Back to basics – meeting customer needs

Customers come to ITC to enlist the help of our acquisition specialists and subject matter experts. We want to provide a convenient, consolidated acquisition experience that is time-efficient and provides the best value to our customers. We currently manage 23 contract programs and more than 4,700 vendors on the Multiple Award Schedule, of which 52% are small businesses. Small and disadvantaged businesses saw a 23% increase in business volume from FY20 to FY21!

Creating taxpayer value – ITC sees record revenue in FY21

Customers buy through GSA to leverage the full buying power of the government. In FY21, we recorded more than $32.3B in business volume through our contracts. For context, this accounts for 35% of the $92.9B total that was appropriated for IT across all federal agencies during the fiscal year. ITC accounted for more than $2.3B in savings to our government customers, a 7.7% increase from FY20.

There is a good reason agencies are using our Office of Management and Budget (OMB) recommended Best-In-Class (BIC) solutions during this pandemic spending period. Our price analysis tools, upfront market research, transactional data, and the great value of offerings on Schedule can’t be found elsewhere. Our success exemplifies the trust that our customer agencies have placed in our ability to help them meet their missions.

Securing the stack – keeping our industry partners accountable

Security mandates such as Supply Chain Risk Management (SCRM), Cybersecurity-Supply Chain Risk Management (C-SCRM), The National Defense Authorization Act (NDAA) 889, and The Executive Order on Improving the Nation’s Cybersecurity are crucial to the nation’s digital and physical safety.

The line between physical and virtual security has blurred as threats have become more complex, and complying with these security mandates is crucial to agency customers. That’s why ITC adds these mandates and others into our master contracts — to streamline proof of compliance for industry and allow agencies to focus on mission delivery.

ITC helps ensure that the products and services our customers buy will comply with federal law and safeguard their network’s security. Large contracts like our 2nd Generation Information Technology (2GIT) hardware/software blanket purchase agreement have SCRM built in as a key operational component.

GSA tools like the new Verified Products Portal (VPP) help identify authorized resellers to enhance SCRM capabilities. Security and cybersecurity approaches and policy are ever-evolving, and GSA recognizes both as core acquisition tenets. We understand the considerable responsibility we have for agencies’ IT health.

Looking ahead

We’re looking forward to finalizing several exciting efforts in 2022. We are bolstering our Cloud marketplace with a one-stop shop BPA, which will be awarded in phases. Polaris (our contract replacement for Alliant 2 Small Business) will release its Request For Proposal in Q2, with awards to be made later in the year. As the September 2022 Enterprise Infrastructure Solutions (EIS) transition deadline quickly approaches, we are in the process of assisting agencies as they award remaining task orders and ultimately disconnect from old telecommunications contracts.

We’ll continue to view things through the lens of our customers, facilitating direct conversations with stakeholders and providing the products, services, and attention needed to achieve agency missions. Our goal is a customer experience that prioritizes cost-efficiency, expediency, and security. You can buy with confidence when you work with the Information Technology Category.

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FY20: Exceptional Work in an Exceptional Year

The Numbers Are In – Biggest Year on Record for GSA ITC!

In Fiscal Year 2020, the Information Technology Category (ITC) recorded more than $30 billion in business volume across its portfolio. For context, this accounts for nearly a third (33%) of the $89 billion total that was spent on IT across all federal agencies in FY20.

Accordingly, this past fiscal year proved to be a record year in other categories as well:

  • IT spending through the Multiple Award Schedule accounted for an impressive $18.1 billion of the $30 Billion total, bolstered by its $12.7 Billion in new obligations. In FY20, MAS IT impressively posted 18% annual growth in new obligations.
  • On the Small Business front, ITC accounted for $7.1 Billion in utilization from Government Wide Acquisition Contracts (GWACs), Schedules, and Telecommunications
  • ITC issued a single award via its telecommunications branch to the tune of $2.5 Billion, using the Enterprise Infrastructure Service (EIS) Contract. The award was made on behalf of the Department of Health and Human Services, and over the lifetime of the contract, the agency estimates it will save more than $700 million.
  • ITC accounted for more than $2 billion in savings and cost avoidance to their customers

FY20 Efforts in Review

The 2020 Fiscal Year drove change through every part of our lives. COVID-19 spurred dramatic change in government work culture and led to rapid technological adaptation across all agencies. A good deal of ITC’s increased business volume can be attributed to agencies transitioning to mobile-friendly technology. However, this unprecedented spending is also due to agencies acknowledging that GSA is a solid partner as they make big IT changes and choices about how to invest. We’re out front and focused when it comes to customer service, agile response to emergency needs, and delivery of mission-enabling and emerging technologies.

In 2020, customer agencies turned to GSA’s schedules program, assisted acquisition services and governmentwide acquisition contracts (GWAC) to fulfill pandemic-driven requirements as well as regular demand for products and services. Our success embodies the trust that federal agencies have put in us and our ability to address elements that our customers most care about:

  • Speed of acquisition
  • Assistance with mobile-friendly technology adoption
  • Technical and market expertise
  • Data transparency
  • General customer service

Agencies have turned to and relied on us to ensure their mission continuity and transition to a more untethered workforce.

In FY20, ITC launched the Information Technology Acquisition University (ITAU) to make it easier to learn about GSA’s products, IT solutions available through GWACs, MAS, and more. ITAU is a digital training platform for emerging technologies, their acquisition, GSA-specific contract training and more.

Additionally, ITC enhanced the Cloud Information Center, the GSA-curated federal resource hub for all things cloud, continuing to place valuable cloud computing resources in the hands of agencies.

These resources are ways that GSA is meeting the rise in demand for virtual access to our subject matter experts and more online learning platforms.

Looking Forward

In FY21, GSA is doubling down on emerging technologies as the way of the future. The 8(a) STARS III and Polaris government-wide acquisition vehicles will have Artificial Intelligence offerings (Machine Learning, Robotic Process Automation, Natural Language Processing), edge computing and more. As the Cybersecurity Maturity Model Certification (CMMC) effort ramps up and Supply Chain Risk Management (SCRM) principles are emphasized, GSA will continue to prioritize security as a core tenet of acquisitions.

As my Deputy Assistant Commissioner Keith Nakasone likes to remind me, agencies are coming to GSA to leverage our IT expertise and the buying power of the government. They want to know that the products they’re adding to their IT footprint aren’t jeopardizing their networks. To that end, the CMMC level can be designated as needed at the task order requirement level. Large contracts such as the 2nd Generation Information Technology (2GIT) hardware/software Blanket Purchase Agreements, have SCRM built in as a key operational component. Ultimately, GSA understands it plays a crucial role and has a considerable responsibility for an agency’s IT health.

Going into FY22, ITC will continue to provide the tools needed to successfully modernize while prioritizing cost-efficiency, expediency, and security. Leveraging Best In Class (BIC) contracts is one way. Taking advantage of online resources like ITAU and the CIC is another. Give your agency a reason to acquire with confidence — work with GSA for your next IT acquisition.

As always, follow us on Twitter @GSA_ITC and LinkedIn to join our ongoing conversations about government IT.
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