The federal government is now requiring that prospective contractors complete electronic annual representations and certifications at http://orca.bpn.gov (ORCA) in conjunction with registration in the Central Contractor Registration (CCR) database. This new requirement eliminates the contractor's administrative burden of submitting the same information to various contracting offices and establishes a common source for this information for contracting offices across the Government.

GSA Schedule solicitations require that vendors fill out the solicitation's representations and certifications as part of the Administrative Volume of their proposal. However, recently updated GSA Schedule solicitations now allow vendors to use their ORCA representations and certifications rather than completing them separately for the GSA proposal. Popular Schedule contracts like Information Technology, Management Organization and Business Process Improvement, and Engineering Services now allow for the use of the electronic ORCA representations and certifications.

Vendors should note that GSA has left the "fill in the blanks" representations and certifications in the solicitations. In some cases, the language that ORCA representations and certifications may be used is included after the "fill in the blanks" requirement. As a result, many complete the solicitation's representations and certifications prior to discovering that their ORCA posting can be used instead. And GSA continues to claim that its solicitations are clear and consultants are not necessary. They should try responding to one of their Schedule solicitations.