As you know, two weeks ago, GSA released its final Order Level Materials (OLM) rule, also known as the “ODC” rule.  It is a significant milestone in GSA’s efforts to further enhance the Multiple Award Schedule (MAS) program to deliver best value commercial solutions to customer agencies though sound business opportunities for MAS contractors.

The OLM rule is a game changer!! It brings increased contract flexibility to meet customer agency needs for integrated, commercial solutions.  It will expand the MAS marketplace, support small business opportunities, and promote innovation.  Significantly, in adding this capability to the schedule contracts, is not only improving its ability to offer best value solutions; it is also tackling unnecessary contract duplication by strategically positioning the Schedules as the commercial, best value contracting vehicle.

Time is of the essence in rolling out the new rule!  As a threshold matter the OLM should be incorporated into MAS contracts on a schedule-wide basis.  There is no policy or business imperative to limit applicability of the new rule to a subset of schedules.  Rather, as a procurement streamlining initiative, the OLM rule can have a positive impact across the entire MAS program.  In addition to schedule-wide adoption, GSA will need to focus on outreach and training for both customer agencies and its industry partners.  Effective training, dedicated FTEs, and vigorous outreach to customer agencies are the key multipliers in facilitating sound, market-wide adoption and use of OLMs.

Training and outreach initiatives also present a great opportunity for GSA and its industry partners to work together towards effective implementation for customer agencies.  Coalition members look forward to working with FAS on this important effort.  To that end, the Coalition is pleased to host Mark Lee, the FAS Assistant Commissioner for Policy and Compliance, at next Tuesday’s Coalition IT/Services Committee meeting.  As the head of the FAS policy office, Mark played a leading role in developing the OLM rule and Coalition members look forward to hearing from him on the rule’s mechanics and GSA’s implementation strategy.

OLMs are a great step forward for the MAS program.  At the same time, there continue to be opportunities to further streamline and enhance the MAS program to increase task order competition, foster transparency, increase access to commercial innovation, and, ultimately, deliver best value to customer agencies and the American people.

Additional opportunities to improve the MAS program include:

  • Standardizing and streamlining the solicitations for the Schedules
  • Improving the customer experience on e-tools like GSA Advantage
  • Adding more visibility and transparency to e-Buy
  • Limiting the proliferation of SINs
  • Eliminating the Price Reductions Clause (PRC) recognizing that price and value are driven at the task order level
  • Increasing consistency in the application of rules and policies across the Schedules program

We are confident that GSA and FAS will focus on improving the MAS program and the Coalition looks forward to working with all stakeholders on this effort.  As FAS Commissioner Alan Thomas stated at the Section 846 public meeting last month, GSA is not standing still as it seeks to improve its programs.  Administrator Murphy’s goals to (1) provide ethical leadership (2) reduce duplication (3) increase competition at the contract and order level, and (4) improve the transparency of the procurement process strategically align with the MAS improvement opportunities.

The OLM rule is the first step.  We look forward to the next steps!