On May 15, 2017, the General Services Administration (GSA) and the Department of Homeland Security (DHS) held an industry day focused on the Continuous Diagnostics and Mitigation (CDM) program.  The meeting covered the future issuance of task orders for Dynamic and Evolving Federal Enterprise Network Defense (DEFEND) via the Alliant GWAC and its follow-on Alliant 2, otherwise referred to as the CDM DEFEND task orders.  Coalition members are very supportive of GSA’s efforts to address access to best in class, commercial CDM capabilities for customer agency cyber security needs.

The CDM DEFEND “two pronged” acquisition strategy will replace the CDM Tools and the CMaaS BPA, the current vehicles through which customer agencies can acquire CDM products.  The Alliant task orders represent one prong while GSA’s IT Schedule 70 represents the other.  Approved CDM products will be listed on IT Schedule 70 and made available for purchase via the Alliant cost reimbursement task orders.  GSA’s FEDSIM will be managing the Alliant competitive task order process in partnership with DHS.

The selection of the Alliant contract vehicle is an appropriate, sound acquisition business decision.  Alliant provides the needed flexibility (e.g., cost reimbursement and ODCs) and scope of services to support CDM DFEND.  Its use also contributes to reducing inappropriate contract duplication while providing an effective contractual framework for program management and administrative support.

At the same time, the CDM DEFEND acquisition strategy highlights the imperative of adding cost reimbursement capability and Other Direct Costs (ODCs) to IT Schedule 70 (see the FAR & Beyond Blog on Professional Services and the MAS Program).   Additionally, it is imperative that the MAS contract terms be clarified to ensure the viability and continuity of BPA periods of performance.  These necessary steps are “proactively customer agency friendly,” providing greater capability to support customer agency mission needs as part of GSA’s overall Multiple Award Schedule (MAS) and GWAC portfolio.

The May 15 industry day slides included a profound statement regarding the past, present and future of the MAS program.  Page 9 of the slides includes a list of “CDM Program Successes to Date.”  Among those listed on page 9 is the following statement:

“Achieved increased savings (~600M) through the consolidation of tool purchases reflecting a 70% cost avoidance compared to IT Schedule 70”

While likely unintended, this statement is misleading in regards to IT Schedule 70 and the MAS program.  The savings and pricing achieved for tool purchases were accomplished through IT Schedule 70 and the MAS ordering procedures.  Consistent with FAR 8.4, GSA competed and awarded Blanket Purchase Agreements (BPAs) for the CDM tools.  MAS BPAs remain a powerful tool to leverage and compete customer agency requirements to achieve best value mission support.  This CDM success story is also, most definitely, a MAS success story.

The savings success of the CDM MAS BPAs highlights that the key to future MAS success is a dynamic, competitive marketplace at the task order level.  GSA’s current focus on MAS contract level pricing, TDR and horizontal price comparisons, although well intended, are costly diversions.  Taking the lessons from the CDM BPAs, it is imperative that GSA invest in, and update, its electronic tools/platforms, streamline processes and reduce burdens for its customer agencies and industry partners.   GSA can lead the future of governmentwide contracting.  It has the tools, the infrastructure, and the talent.  Will GSA embrace the opportunity?