Off the Shelf

Phil Christy, principal executive director, Office of Acquisition, Logistics, and Construction (OLAC), and chief acquisition officer at the Department of Veterans Affairs, joins Off the Shelf for update on VA acquisition operations.
Christy provides his acquisition vision as the VA reorganizes its acquisition workforce, and shares the key priorities and goals for the restructuring and what it means for the workforce, mission, and industry partners.
He addresses the key management considerations driving change with the goal of enhancing consistency of operations, driving accountability, creating efficiencies in operations, and leveraging standardization.

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Tim Brennan, president of the Center for Procurement Advocacy, joins Off the Shelf for a spotlight on the year end legislative priorities for Congress.
Brennan identifies the principal legislative priorities before year end, including FY27 appropriations and the NDAA, and shares how he sees the calendar playing out and how the election results may impact approaches to moving forward on appropriations and the NDAA.
He notes the multiple funding and authorization deadlines that are converging in December and how Congress may resolve them.
Brennan also discusses potential NDAA acquisition priorities, highlighting the continuing focus on commercial acquisition, intellectual and technical data requirements, and supply-chain resiliency.
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Jason Workmaster, member at Miller & Chevalier, joins Off the Shelf for procurement potpourri, highlighting some of the current developments in federal procurement policy, law, and operations.
Workmaster gives his assessment of the Revolutionary Federal Acquisition Regulation (FAR) Overhaul (the RFO), ad shares his thoughts on whether the RFO, specifically the FAR Part 15 rewrite, will reduce the risk of protest.
He also provides his insights regarding a series of policy and contracting issues surrounding GSA’s Multiple Award Schedule (MAS) program, including the potential outcome surrounding GSA’s RFI targeting resellers.
The discussion turns to the so-called “MAS Blogger’s” recent post regarding the use of e-Commerce platforms to fill MAS orders.
Other topics include the role of bid protests involving Other Transactions Authority (OTAs) and Commercial Solutions Openings (CSOs).
Finally, Workmaster covers a recent decision addressing the constitutionality of the role of relators under the Civil False Claims Act.
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Ken Dodds, executive vice president and general counsel at The Coalition for Common Sense in Government Procurement, joins Off the Shelf for a timely and in-depth discussion of the Small Business Administration’s (SBA’s) proposed rule amending the size standards.
The proposed rule makes significant changes to the size standards. For example, the size standard for IT services goes from $34 million to $531 million and the size standard for consulting services goes from $24.5 million to $295 million.
Dodds discusses the implications of the proposed changes, including the impact on competition across the federal market as well as the potential impact on current small, medium, and large businesses.
He also provides a tutorial on the basics of the non-manufacturer rule, including what happens when the rule is waived for a procurement.
Finally, Dodds shares his thoughts on GSA’s proposed AI clause versus commercial practice.
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Michael Gruden, partner at Steptoe LLP, joins Off the Shelf for the latest on cybersecurity and government contracts compliance.
The conversation focuses on “CMMC to Be or Not to Be” where Gruden provides his insights and assessment of the CMMC journey to date and in the future.
He outlines the considerations playing into the CMMC pause and what he expects moving forward.
Gruden also shares some best practices for cyber compliance across the federal contracting landscape, and he give his thoughts regarding the Revolutionary FAR Overhaul (RFO) and the new Controlled Unclassified Information (CUI) guidance in FAR Part 40.
Finally, Michael talks about Cyber Incident Reporting for Critical Infrastructure Act (CIRCIA) rule making and what can be expected.

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