FAR and Beyond Blog

This week’s comment was to focus on five steps to improve requirements development and procurement outcomes for the American people.  It will have to wait till December.  A recent article in Federal Times entitled “GSA exploring cost-reimbursable option to Supply Schedule” has drawn me back, like a moth to a flame, to other direct costs (ODCs) and the Multiple Award Schedule program.

According to the article, FAS Commissioner Tom Sharpe stated to Federal Times that GSA is exploring adding a cost-reimbursement contract option to the MAS program.  The Coalition appreciates and supports GSA examining all options that may further support customer agency needs through pre-existing government-wide contract vehicles.  We look forward to the dialogue with GSA as it explores the business and procurement policy case regarding cost-reimbursement schedule contracts.

At the same time, GSA has a “low hanging fruit” opportunity to reduce contract duplication and total acquisition costs across the federal enterprise by authorizing customer agencies to utilize the Federal Acquisition Regulation (FAR) based commercial item clause for ODCs.   The FAR-based clause, 52.212-4, Alternate I, already authorizes a contract mechanism for competing, acquiring and reimbursing contractors, at the order level, for ODCs, materials and indirect clauses.  FAR 52.212-1, Alternate I went through the ruling making process over five years ago.  So today there is a clause (52.212-4, Alternate I) that can immediately serve customer agencies by increasing competition through the MAS program for best value commercial solutions.   Increasing MAS competition, capability and efficiency for the acquisition of commercial solutions will reduce contract duplication!  Agencies will not have to create their own contract vehicles when the MAS program can meet their requirements.

At GSA’s request, the Coalition prepared a White Paper addressing the implementation of ODCs on MAS contracts.  The paper can be found here.  The roadmap is there and we look forward to GSA adding this cost saving contracting capability to the MAS program.  After all, ODCs will benefit customer agencies and the American people by providing a more capable, robust and competitive MAS program.  It is a win-win for all.  It is time to pick the low hanging fruit!

Roger Waldron

President

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