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:
- Putting “Commercial” Back into Commercial Item Contracting
- Promoting Effective Contracting and Access to Innovation
- Streamlining Procurement Processes
- Reducing Unnecessary Regulatory Burdens
- Reducing Contract Duplication
Coalition member companies offer some of the most innovative technologies, products and solutions available in the commercial market. As an association, the Coalition advocates for putting “commercial” back in commercial item contracting so that the Federal government can benefit from the efficiencies, innovation, and competitive pricing commercially available.
Recently, the proverbial pendulum has continued to swing away from commercial item contracting through increased government unique policies, procedures, and requirements. Within the past year, examples of this shift include GSA’s commercial supplier agreement (CSA) class deviation, the proposed transactional data reporting rule, and the Department of Defense (DoD) proposed rule on fair and reasonable pricing. If implemented as proposed, the cumulative impact would significantly increase risks and barriers for commercial companies in the Federal market—at a time when the government is seeking to increase access to commercial innovation.
In response, the Coalition has continued to call for the identification and elimination of policies, procedures, and requirements that are inconsistent with commercial practice. For the CSA class deviation request for information, the transactional data proposed rule, and the DoD fair and reasonable pricing proposed rule, the Coalition submitted public comments, established working groups to provide direct feedback through Myth-busters dialogues, and shared specific figures with the government on information collection burdens.
Moving forward, the Coalition will continue to advocate for putting “commercial” back in commercial item contracting with GSA, DoD, and other government agencies.
As part of the Myth-buster’s Campaign, the government seeks industry input as a key stakeholder in the development of major contract programs. Two examples of this in the past year were the Alliant 2 contract for comprehensive information technology (IT) solutions and the Human Capital and Training Solutions (HCaTS) contract developed for the Office of Personnel Management (OPM) for government-wide use. Significantly, Coalition members provided input to the government on the acquisition strategy for both Alliant 2 and HCaTS.
The Coalition prides itself on providing opportunities for industry leaders to work directly with government officials through various channels of communication, including webinars, Working Groups, and breakout sessions. For instance, our popular monthly webinars with GSA’s Alliant 2 this past year enabled industry to hear directly from GSA as they developed their acquisition strategy. Participants were able to have questions and raise concerns in real time with the Alliant 2 team. Further, for both Alliant 2 and HCaTS, the Coalition established Working Groups for our members to share ideas and develop comments that helped shape policy decisions. Members were able to focus on meeting the needs of Federal partners, while also maximizing competition and promoting common sense procurement strategies.
In addition, the Coalition’s Spring and Fall training conferences enable our members to work face-to-face with leading Federal procurement executives on the latest policy developments. The all-day conferences provide members with plenty of time to have meaningful dialogues and establish positive relationships with government policy makers. The Coalition looks forward to offering similar opportunities for members on upcoming contract vehicles in 2016.
Simplifying procedures in the Federal acquisition process yields cost saving efficiencies for both government and industry, as well as faster availability of products and services for customer agencies. The Coalition supports streamlining procurement processes government-wide. Members have especially been interested in more streamlined and consistent procedures within the GSA Schedules program.
GSA has been taking actions to simplify some of the processes and requirements for GSA Schedules. At the Coalition’s Spring Conference in April 2015, GSA Administrator Denise Turner Roth spoke to members about the progress that the agency made on a number of “Quick Fix” recommendations developed by the Coalition to streamline processes and requirements within the Schedules program. Such recommendations included automatically approving administrative changes, increasing the transparency of eBuy, and discontinuing requests for “most favored federal customer.”
In addition, GSA has also adopted streamlined procedures for successful legacy contractors as part of the Contract Continuation Initiative, launched in November 2015. The streamlined procedures were presented to GSA in the Coalition’s Evergreen White Paper. In short, Evergreen contractors nearing the end of the 20-year period of their Schedule contract will not be required to submit certain information for the new contract offer such as financial statements and relevant project experience. Industry will continue to discuss the benefits of these changes in 2016.
To achieve efficiencies in Federal procurement, the government must reduce the unnecessary regulations involved that complicate the process for government and industry.
Recent efforts, such as the Administrator for Federal Procurement Policy, Anne Rung’s 2014 memorandum entitled Transforming the Marketplace: Simplifying Federal Procurement to Improve Performance, Drive Innovation, and Increase Savings and GSA Administrator Denise Turner Roth identification of “Making It Easier for Suppliers to Work with the Government” as a top priority, demonstrate a serious effort on behalf of the government to make Federal procurement less burdensome
The Coalition supports such efforts by OFPP and GSA’s to reduce the regulatory requirements that cause the greatest burdens for contractors. Indeed, over the past year, the Coalition continued to call for the elimination of the Price Reductions Clause (PRC) as described in our Multiple Award Schedule Pricing Policy White Paper. Based on a survey of Coalition members, Schedule contractors spend more than 1,200 hours annually on PRC compliance at a cost of more than $125,000 per company. Given that pricing under the Schedules today is driven by competition and not the PRC, maintaining it as central to the MAS program is costly, inefficient, and without added value to customer agencies. The Coalition will continue to request that the PRC be eliminated in 2016.
The number of duplicative contracts for the same products and services across the Federal government is a major concern. Duplicative contracts increase bid, proposal, and contract administration costs for both government and industry; costs that could be avoided through greater use of interagency contracts. Government-wide multiple award contracts, such as Government-wide Acquisition Contracts (GWACs) and GSA MAS contracts, provide a streamlined competitive ordering process that save time and money in the bid proposal context.
Through the Category Management initiative, the Federal government is looking to use its cumulative buying power under existing contracts to save costs and increase efficiency. In 2015, Federal Chief Information Officer Tony Scott and OFPP Administrator Anne Rung released a memorandum directing agencies to reduce the number of contracts for laptops and desktops by consolidating purchasing under 3 high performing contracts—GSA Schedule 70, NASA SEWP, and NITAAC CIO-CS. At GSA, a major consolidation under the Schedules program was achieved. 8 professional service Schedules were consolidated into one Professional Services Schedule. The consolidation increased program efficiency and reduced administrative costs for both the government and industry. The Coalition, through committee and other member meetings, expressed support for this initiative.
The Coalition supports reducing contract duplication further through increased use of existing contracts under Category Management. We continue to look for opportunities to promote the use of existing contracts by agencies, rather than spending taxpayer funds on new contract programs.