For more than 35 years, the Coalition has provided members with unparalleled service in the realm of procurement policy. We track key policy issues and advise members on the latest developments in Federal contract regulation and legislation.
Voicing member interests to the Federal Government is central to the Coalition’s policy involvement. Government often turns to the Coalition for feedback and insight when launching new procurement programs and policies. The following are just some of the policy matters that the Coalition is currently engaged in:
- Reforming the GSA Schedules Program
- Simplifying and Improving the Federal Procurement Process
- Reducing Contract Duplication
- Focusing on Best Value and Total Acquisition Cost
- Increasing Innovation
At $40 billion annually, the GSA Schedule is the largest commercial item program in government. It is unique in its ability to provide a single platform that accommodates government-wide requirements for commercial items.
Despite the value and size of the program, the GSA Schedules are in need of reform—from major policy and regulatory changes to simple administrative changes that implemented agency-wide would greatly increase the efficiency and effectiveness of the program.
The Coalition recommended the following four key pricing policy changes in its MAS Pricing Policy White Paper to improve the Schedules program:
- Eliminating the Price Reduction Clause (PRC)
- Deleting the phrases “Most Favored Customer” and “Best Price” from the pricing policy
- Pilot testing a Services Acquisition Reform Act (SARA) Acquisition Advisory Panel recommendation for a professional services schedule where specific pricing would be set by competition at the task order level rather than Most Favored Customer negotiations at the contract level
- Reviewing and revising the commercial sales practices disclosure format
In addition to major policy changes, the Coalition has suggested a number of “Quick Fixes to the MAS Program” that would reduce transactional costs, increase efficiency, and increase access to commercial products and services.
The Coalition continues to advocate for improving the efficiency and effectiveness of the Federal procurement process. By simplifying Federal purchasing, the government can reduce costs, improve performance and increase access to innovative solutions.
In response to a major initiative in 2014 launched by the Chief Acquisition Officers Council, the Office of Federal Procurement Policy (OFPP) and other government entities, the Coalition submitted number of recommendations that called for the simplification of the acquisition process, removal of unnecessary barriers to the Federal market and the reduction of contract duplication by strengthening OFPP’s business case review process. The Coalition also recommends that the government strengthen and enhance commercial item contracting and conduct a retrospective review of procurement regulations.
Contractors continue to be concerned about the increase in Federal contracts government-wide that offer the same or similar services and products. Duplicative contracts increase bid, proposal and contract administration costs for both government and industry—costs that could be avoided through greater use of pre-existing interagency contracts like Government-wide Acquisition Contracts (GWACs) and GSA Schedule contracts. The Coalition recommends that the government use pre-existing interagency contracts like Government-wide Acquisition Contracts (GWACs) and GSA Schedule contracts to the maximum extent practicable.
In the current budget environment, commercial contractors have seen an unprecedented focus by the government on driving down pricing at the contract level “at all costs.” As an example, GSA is using historical, horizontal price comparisons to drive down pricing in the Schedules program. Unfortunately, these price comparisons too often ignore differing terms and conditions, market conditions and even volume commitments. The strategy also ignores the fact that the Schedule level pricing is largely irrelevant because actual prices paid by customer agencies are determined at the task order level at which point they are driven down by competition.
Instead of this approach, the Coalition promotes “best value” procurement recognizing that there are factors in addition to price that are important to government customers. Quality, delivery time and compliance with certain government unique requirements are examples. Purchasing based on best value can also accommodate total acquisition costs beyond the price at the point of sale. Total acquisition costs include maintenance costs and quality (e.g. the performance level of the product or service received, replacement costs, etc). The government’s current pricing model ignores these additional factors which are key to the government getting the best deal for the taxpayer.
The Coalition also focuses on increasing innovation in government procurement. We have promoted three steps towards innovation that would encourage greater competition, efficiency, value and access to the commercial marketplace. They are:
- Transforming IT Schedule 70 into the IT Commercial Innovation Schedule
- Updating the General Services Acquisition Regulation (GSAR) pricing policies
- Revising or eliminating burdensome contracting procedures and restrictive solicitation terms and conditions