March 1, 2013—Sequestration Day. This morning our 13 year-old son was reading the Wall Street Journal article on sequestration and asked me a question only a kid could ask: “So Dad, if I had a penny would I have more money than the government?” His question led to a long conversation about the budget, how debt works, and the mechanics of sequestration. It was one of those family conversations that you will always remember.
On my drive in to work this morning I kept thinking about our conversation and Thought No. 6 of the Thirteen Thoughts for 2013: Put “commercial” back in commercial item contracting.” Putting “commercial” back in commercial item contracting will foster savings, efficiency, competition and innovation for the customer agencies and the taxpayer. Over the last decade, the proverbial pendulum has swung regarding policy, procedures and requirements imposed on commercial item contracting. By way of example, in 1996 there were 17 provisions of law or executive order applicable or potentially applicable to commercial item contracts. By 2012, the number had grown to 51 provisions! In addition, the level of oversight and data reporting associated with commercial item contracting programs like GSA’s Multiple Award Schedule (MAS) program have increased significantly.
Identifying and eliminating policies, procedures and requirements that are inconsistent with commercial practice is consistent with President Obama’s Executive Order 13563—Improving Regulation and Regulatory Review and Executive Order 13610—Identifying and Reducing Regulatory Burdens. In sum, these executive orders provide direction to agencies to review and eliminate regulations where the costs outweigh the benefits. It is looking at Total Acquisition Cost versus just price. This approach is good for government, good for the taxpayer and ultimately good for the economy. As Executive Order 13610 states, “[d]uring challenging economic times, we should be especially careful not to impose unjustified regulatory requirements.”
In the spirit of the President’s executive order, the comment of the week highlights the Price Reduction Clause (PRC) as an unjustified regulatory requirement. The PRC is costly and irrelevant to the MAS program. The PRC is inconsistent with the current competitive ordering requirements of the MAS program. Statute and regulation require that for all orders exceeding $150,000 under the MAS program, customer agencies must give all MAS contractors capable of meeting the requirement notice and an opportunity to compete for the order. e-Buy, GSA’s electronic quote system for the MAS program, provides customer agencies with the ability to provide notice to all contractors. In FY12, over 80,000 Requests for Quotes were posted on e-Buy by customer agencies. As such, pricing is being driven by competition for agency requirements at the task order level. It is not being driven by the PRC. At the same time, the PRC increases costs to MAS contractors in contract administration and compliance—costs that especially hurt small business. Moreover, the PRC is an anti-competition, anti-growth provision. The PRC restricts competition in the private sector. It is the potential for MAS contract liability when a MAS contractor offers a price reduction to a commercial customer for a commercial requirement that restricts the ability to fully compete in the commercial marketplace. In turn, this restriction on competition in private, commercial transactions limits growth and job creation. It is time to reform the PRC.
Reducing the growing burden on commercial item contracting will streamline the acquisition process creating greater opportunity for entry into the federal marketplace by commercial firms. At the same time, the growing complexity of federal procurement has led to commercial firms managing risk by creating separate legal entities to deal with the federal government. This is inefficient and counter to the government’s efforts to reduce transactional costs across the procurement system. Putting “commercial” back in commercial item contracting will reduce risk and increase efficiency for all. The Coalition looks forward to continuing the dialogue with the entire procurement community regarding total acquisition cost and commercial practices.
This Wednesday, three top Federal budget experts spoke about sequestration and the budget outlook at a special event for Premier and Keystone members at General Dynamics. Stan Collender with Qorvis Communications provided insight into the politics of sequestration being played out between the White House and the Hill. He advised that no one should take anything that happens in the run up to March 1 as a sign of what is actually going to happen. After the sequester kicks in on March 1, contractors should brace for more budget uncertainty. “This is the new normal,” Collender said as he suggested that continuing resolutions and Congressional gridlock will continue for the next 3 to 4 years. Regarding the sequester, Collender believes that after the cuts are triggered, pressure will build sometime in mid-March pushing Congress to either cancel the cuts or devise an alternative. “The longer the sequester goes on, the more painful things will be,” Collender said.
Members also heard from Ray Bjorklund of Deltek and Cameron Leuthy of Bloomberg Government. Ray and Cameron echoed Stan’s comments on continuing budget uncertainty and difficulties for contractors. They also added words of encouragement. “This is something we can all get through,” said Ray Bjorklund. Cameron Leuthy noted that for sequestration, the government is more likely to extend a contract rather than conduct a re-compete. Ray and Cameron also stressed that there will be less Federal dollars for contractors to win resulting in increased competition as contractors battle each other for market share.
The Coalition sincerely appreciates Stan Collender with Qorvis Communications, Ray Bjorklund with Deltek, and Cameron Leuthy with Bloomberg Government for sharing their expertise at our Premier event. As always, we also thank our Keystone and Premier members for their support!
OMB Controller Danny Werfel released guidance to Federal agencies this Tuesday on the implementation of sequestration. Given that $85 billion in budgetary cuts will be implemented over the remaining seven months of the fiscal year, OMB estimates that “effective percentage reductions are approximately 9 percent for nondefense programs and 13 percent for defense programs.” OMB outlined in the memo how agencies should implement the cuts in five areas:
- Acquisition. “Sequestration will inevitably affect agency contracting activities… and reduce contracting costs where appropriate,” the memo states. Werfel also noted that contract actions should be cost-effective and minimize the negative impact on the agency’s mission to the extent practical. In addition, “agencies should only enter into new contracts or exercise options when they support high-priority initiatives or where failure to do so would significantly cost the government more in the future.” Further, agencies may also consider de-scoping or terminating for convenience contracts that are no longer affordable within the funds available for Fiscal Year 2013, should no other options exist to reduce contract costs. If these actions are deemed necessary through cost-benefit analysis, agencies must appropriately inform and negotiate with contractors. All actions should attempt to minimize the impact on small businesses.
- Planning activities. While referring to OMB Memorandum 13-03, Werfel notes that planning efforts for agencies should be “guided by the principle of protecting the agency’s mission to serve the public to the greatest extent practicable.” This includes indentifying any major contracts that they plan to cancel, re-scope or delay.
- Communications. OMB stresses that agencies should be communicating with various partners and stakeholders in a timely and complete manner about the impact of sequestration so that third parties can adjust their operations and plans as appropriate.
- Financial Assistance. OMB cautions against awarding any new financial assistance obligations, and notes that reducing or renegotiating current funding are options when implementing the sequester.
- Increased scrutiny of certain activities. OMB explains that these areas include the hiring of new personnel, federal employee bonuses, and new obligations for training, conferences, and travel.
The House Committee on Oversight and Government Reform held its second hearing this week about how to best reform the acquisition of information technology (IT). Testimony from public and private sector acquisition experts provided the committee with valuable stakeholder input on IT Acquisition Reform legislation drafted by Chairman Darrell Issa. The bill, known as the Federal IT Acquisition Reform Act (FITARA), is expected to be introduced by Chairman Issa by late March.
FITARA is designed to address program failures and cost overruns in the acquisition of IT, which the committee estimates the government spends $81 billion on each year. As drafted, legislation would increase Chief Information Officer (CIO) budget authority and encourage more transition to cloud solutions, use of open source software, and support data center optimization. The bill would also designate certain agencies as Assisted Acquisition Centers of Excellence which other agencies could use for certain complex IT procurements.
Testimony during the hearing was provided by:
- Mr. Richard Spires, Chief Information Officer, Department of Homeland Security
- Ms. Cristina Chaplain Director, Acquisition and Sourcing Management, Government Accountability Office
- The Honorable Daniel Gordon, Associate Dean for Government Procurement Law Studies at the George Washington University Law School; Former Administrator, Office of Federal Procurement Policy, Office of Management and Budget
- Mr. Stan Soloway, President and CEO, Professional Services Council
- Mr. Paul Misener, Vice President, Global Public Policy, Amazon.com
During the hearing, Chairman Issa emphasized that the bill would envision the Federal government as a single purchasing entity. As a result, there was a good amount of discussion on the potential benefits of strategic sourcing IT and associated services. Issa also stressed the importance of pricing transparency in IT acquisition, which would include not only agencies ability to see the prices paid by other agencies, but also make other pricing data such as cost available to the government. The committee is interested in hearing industry feedback on this concept.
Former OFPP Director, Dan Gordon, reinforced the critical role of the acquisition workforce and the need to empower these personnel to make sound business decisions, such as choosing best value over low price technically acceptable where appropriate. However, he cautioned that many of the biggest challenges in IT acquisition are management issues that do not necessarily lend themselves to a legislative solution. Gordon also emphasized the importance of open communications between government and industry during requirements development and suggested that the committee consider a “myth-busters” component to the bill.
In a February 21 memo obtained by Defense News, Frank Kendall, undersecretary of defense for acquisition, technology and logistics at the Department of Defense (DoD) gave the go ahead for the department to speak with contractors about sequestration. In the memo, Kendall emphasized that Defense officials should “keep industry informed about our plans and involved in our decision-making process to the maximum extent possible, particularly when ongoing or upcoming contracts may be affected”. Kendall also noted that the DoD contracting community is “authorized and encouraged to have discussions with industry as they finalize plans relative to potential sequestration and continuing resolution impacts.”
The memo also says that DoD discussions with industry will help companies “to more productively make their own internal business plans.” For DoD, industry can also provide “feedback that could provide valuable insights as government managers decide how best to move forward in attempting to meet war-fighter requirements and DoD needs.”
The Government Accountability Office (GAO) testified before the House Committee on Oversight and Government Reform this week on the strategic sourcing of information technology (IT). During the committee’s hearing on IT acquisition reform, GAO emphasized the savings that leading companies have achieved through strategic sourcing, about 10 to 20 percent, and recommended that Federal agencies do more. GAO stated that, “if implemented effectively, billions of dollars in potential savings may be realized, providing agencies with a valuable tool for maximizing their ability to carry out critical missions under tight budgets.”
In order to effectively strategically source IT and other items, GAO suggested that the government needs to do a better job of collecting and analyzing procurement spending data, gain senior leadership support, and monitor progress against established goals to measure any savings achieved.
GAO also suggested that strategic sourcing should not be limited to products, but also to higher spend categories like IT services. GAO noted Federal agency reluctance to strategically source services, but said that leading companies had done so in the past 5 to 7 years with positive results. Telecommunications and IT services were two areas that these companies reported success with strategic sourcing. However, the companies surveyed by the GAO also viewed IT services as complex, requiring attention to the trade-offs between price and quality.
GAO’s testimony on IT strategic sourcing is posted at www.gao.gov/products/GAO-13-408T.
On February 25, Defense Procurement and Acquisition Policy (DPAP) issued a memorandum providing instructions to Department of Defense (DoD) contracting officers about coding functions closely associated with inherently governmental functions, critical functions, and other functions in the Federal Procurement Data System (FPDS). This requirement was originally included in guidance issued by the Office of Federal Procurement Policy (OFPP) in 2011. According to Richard Ginman, DPAP director, identifying closely associated and critical functions at the time of award should assist agencies in prioritizing which contracts may require increased management attention and oversight to ensure that mission creep does not result in contractors performing inherently governmental functions and to ensure that the agency does not lose control of its mission and operations. The memorandum states that the instructions apply to new awards dated March 1, 2013 and later, as well as modifications to those new awards.
In a recent article in the March-April 2013 issue of Defense AT&L magazine, under secretary of defense for acquisition, technology, and logistics, Frank Kendall, explains the use of fixed-price incentive (FPI) contracts. In the article, Kendall notes that while the original Better Buying Power (BBP) encouraged the use of fixed-price incentive (FPI) contracts, BBP 2.0 modifies this guidance to stress using appropriate contract types while continuing to encourage use of FPI for early production. Kendall also provides some examples of “appropriate” situations for given contract types. As an example, prior to approving FPI for engineering and manufacturing development, Kendall lists five prerequisites:
- Firm requirements: Cost vs. performance trades are essentially complete. In this case, DoD has a “very clear understanding of what we want the contractor to build, and we are confident that the conditions exist to permit the design of an affordable product that the user will be able to afford and is committed to acquiring.”
- Low technical risk: Design content is established and the components are mature technologies.
- Qualified suppliers: Bidders will be firms that have experience with this kind of product and can be expected to bid rationally and perform to plan.
- Financial capacity to absorb overruns: Responsible contractors who have the capacity to continue and deliver the product despite potential overruns that may not have been foreseeable.
- Motivation to continue: Kendall also stresses that a “business case must be provided via a prospective reasonable return from production that will motivate suppliers to continue performance in the event of an unanticipated overrun. It is unrealistic to believe contractors will simply accept large losses. They will not.”
What Does 2013 Have In Store for Government Contractors and Their Lawyers?
By Louis Victorino, Partner, Sheppard Mullin and Jonathan Aronie, Partner, Sheppard Mullin (originally published in the San Diego Business Journal)
It has been noted, the more things change, the more they stay the same. In the world of Government Contracts Law, however, the more things change, the more the phone rings. And while we’re only a month into 2013, the phone has been ringing off the hook. Here are a few of the reasons why.
The Government’s anti-contractor bias continues unabated. From the moment President Obama stepped into office, his executive team made clear their distrust of defense contractors. Indeed, one of OMB’s first public pronouncements focused on curbing perceived rampant contractor fraud. Shortly thereafter, Congress passed the Close The Contractor Fraud Loophole Act, certainly not the title one gives to an Act intended to extoll the virtues of the long and critical partnership between Government and industry. In late 2008, the Government continued down the anti-contractor path when it created what is known as the Mandatory Disclosure Rule, a regulation that requires contractors to self-report “credible evidence” of an extremely broad list of potential wrongdoing. The purported rationale for the rule? The Government’s belief that contractors were affirmatively hiding their fraudulent activities from the Government. Putting aside for a moment the many flaws in the Government’s apparent view that contractors generally are not to be trusted, the fact is the anti-contractor bias remains strong in 2013 and shows no signs of abating.
Increased enforcement activities. Tied closely to the Government’s view that contractors are not to be trusted, is the Government’s ever-increasing efforts to police those contractors more aggressively. Like 2012 before it, 2013 is poised to see increases in federal audits, investigations, and False Claims Act lawsuits. DCAA, the Defense Department’s primary audit watchdog, for example, continues to reach new levels of aggressiveness. As one commentator put it not long ago, the DCAA “is out of control.” Suspensions and debarments also are likely to increase in 2013. The President has directed federal agencies to make better use of the suspension/debarment process, and the OMB is making sure the President’s direction is implemented. It would be naïve, of course, to think this increase in enforcement activity is due solely to a mistrust of contractors. The Government’s collection of $4.9 Billion (yes, that’s Billion with a B) in False Claims Act settlements and recoveries in 2012 no doubt feeds the Government’s view that contractors need more policing, and fuels the arguments of the enforcement community that they need to be more, not less, aggressive.
Shrinking pots of money mean more bid protests. The number of bid protests (that is, disputes between a contractor and an agency over the non-award of a federal contract) has increased every year since 2008. In 2008, 1,652 actions were filed with the General Accountability Office (GAO), the primary arbiter of procurement award disputes. That number steadily increased to 2,475 in 2012. Whether or not that number will rise again in 2013 remains to be seen, but the likelihood that larger award decisions will be protested by a disappointed bidder will increase. As federal opportunities become fewer, the competition for those that remain almost certainly will heat up. In short, some companies simply cannot afford not to protest.
The Government will take more work in-house. With shrinking budgets and the elimination of programs, the Government will bring more work in-house in 2013 to maintain their internal funding levels and workforce headcounts. The move to in-sourcing will be advocated by Government labor “unions” and supported by the Democratic administration. See, e.g., Subtitle C of Title III of the National Defense Authorization Act for Fiscal Year 2012. This won’t just be in-sourcing of traditional Systems Engineering and Technical Assistance (SETA) work and weapons depot work, but will extend to major weapon systems repairs and overhaul, as well as design, development, and implementation of major Government software system upgrades. We also likely will see that Government engineering centers and laboratories will move to keep in-house significant research and development funding and activities. These efforts will have an obvious significant impact on contracting opportunities available to private companies, large and small.
The Government will become more aggressive with respect to securing intellectual property. As a consequence of bringing more work in-house, the Government will need the intellectual property necessary to perform that newly in-sourced work. As a result, 2013 likely will manifest an acceleration of recent trends to a more confiscatory Government policy regarding rights in data, including patents and copyright. Regardless of the standard rights in data delineated in applicable regulations and contract clauses, in connection with the solicitation of contracts for major programs, the Government will seek to obtain, at a minimum, a Government Purpose Rights License not only to data first produced or developed under the contract but also to a significant portion of all data used in the performance of the contract. Definitions of “Commercial Items” will be narrowed, expanding the Government’s rights in data, including software. Formal challenges to current contractor claims of data rights will increase. And, unfortunately, in some instances, contractor intellectual property simply will be used by the Government, with the propriety of the use left to be determined by years of litigation.
Greater competition for fewer dollars will prompt industry consolidation. The reduced number of contracting opportunities will have many collateral impacts on the Government contracting community and their legal advisors. As occurred with the end of the “cold war,” there likely will be an upswing in industry consolidation. With a reduction in funding and new programs available to contractors, the industry base will need to shrink. Some commercial and “dual use” companies simply will abandon the market. Others, with shrinking backlogs, will seek strength and economies through corporate combinations or “spin-offs.” Some companies, particularly smaller companies, will be targets of acquisition because of their success in winning large or significant program contracts. A business that wishes to be the leader in a particular technology may well need to acquire the winning competitor of the next and only large, long term contract involving that technology.
The increased pressure that comes with increased competition will cause some to stray. While the federal contracting community is, far and away, one of the most self-policed industries in the country, every industry has its exceptions. While most contractors will assess the new environment and adapt their business strategy accordingly, some will bend to the new fiscal pressures and adapt their strategies in more reckless ways. When contractor managers and employees see their livelihoods hitched to the success of the next proposal submission, some will do foolish things – some will seek inside information regarding the procurement, seek proprietary information about their competitors, provide false information to support their offer such as “inflated” resumes or product performance claims, and any number of other prohibited activities. In short, some people do pretty stupid things when they are under pressure. Fortunately, these events are the exception rather than the rule, but companies cannot afford to take any chances. If contractor leadership is not extremely vigilant and committed to internal integrity and compliance, the increased audits and investigations described above may well negate all efforts to be successful in the new smaller, Government contracting market.
Contractors continue to embrace ethics and compliance as a core element of success. Years ago, the implementation of an in-house ethics and compliance program was viewed by many contractors as a necessary evil; something needed to keep the lawyers happy, but rarely embraced by the “revenue generators.” Over the last 5-10 years, however, there has been a cultural shift among contractors. Contractors now embrace the benefits of an effective ethics and compliance program. Codes of Conduct are the rule rather than the exception. Training programs are standard fare for Government contractors. While the Government can take some credit for this evolution – there is nothing like a few multi-million dollar False Claims Act settlements in your industry to highlight the importance of compliance – contractors also deserve much of the credit for embracing the benefits of such programs. As the Government’s enforcement activities become more and more aggressive, one can expect to see a continued increase in the roster of Company’s embracing the benefits of an effective internal control system and ethics/compliance program.
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In short, we are reminded of an observation provided by an astute securities law school professor who noted: When the stock price of a company goes up, stock sellers will sue the buyers. When the stock price goes down, the buyers will sue the sellers. When the stock price remains the same, each will sue the other. Government contracting is a challenging market. Challenges exists in up-times and they exist in down-times. They likely will be different challenges from year to year, but challenges always are present. The astute contractor understands this and guides the organization accordingly.
The 2013 market clearly counsels in favor of enhanced care in the pursuit of new business. With respect to new solicitations, assure that the proposed terms and conditions and the statement of work/specifications are reviewed carefully and risks identified. Assure decisions to accept risk are fully informed and made at an appropriate level within the company. Finally, refresh your internal personnel training regarding Government and company rules delineating what are prohibited activities in connection with the submittal of a proposal. And, if all else fails, pick up the phone and give your friendly Government Contracts lawyer a call. You won’t be alone.
This article formed the basis, in part, for an article appearing in the January 21-27 issue of the San Diego Business Journal (www.sdbj.com) and special thanks to the editors of that publication for permission for its re-use.
On February 27, the House Small Business Committee conducted a markup of its “Views and Estimates” which lays out the Committee’s recommendations to improve SBA performance and services to small businesses. Included in the report are recommendations for the SBA’s Federal Contracting Programs. The report states that procurement center representatives (PCRs) make up less than 3 percent of personnel at the agency. “[PCRs] constitute the SBA’s front line in promoting the use of small businesses and first line of defense against contract bundling… [F]unds should be reallocated so that the SBA actually dedicates the necessary personnel so that PCRs can perform their jobs in an effective manner, rather than the current situation in which the approximately 60 PCRs must each review about $8.6 billion in government contracts.” The committee recommends that SBA dedicate additional resources to defend against vulnerabilities in its contracting programs—such as a business misrepresenting its size or status—by making sure that there are “adequate personnel to check the small businesses and updated databases for use by contractors and federal contracting officers.” Materials from the markup can be found on the Small Business Committee’s website.
The Department of the Navy has posted a sources sought notice on FedBizOpps.gov for an Electronic Procurement System (EPS) capability to replace the contract writing capabilities of the Department of Defense (DOD) Standard Procurement System (SPS). The notice suggests that the new system could also potentially replace the capabilities of the Navy’s other legacy contract writing systems. The Department of the Navy (DON) is seeking information regarding the potential of the market to provide an EPS.
According to NextGov, DoD is looking for new tools because Frank Kendall, undersecretary of Defense for acquisition, technology and logistics, mandated that the Standard Procurement System be phased out by September 2015 and directed the services to develop their own systems for contract writing and administration. For more information, please review the notice on FedBizOpps.gov.
The Coalition submitted comments this week in response to a proposed rule concerning the Industrial Funding Fee (IFF). As part of the GSAM rewrite project, GSA submitted a proposed rule to amend GSAR 552.238-74 to make it clear that the IFF is used not only to fund the MAS program, but also to fund and offset losses in other FAS programs. The proposed rule also requested comments on the information collection burden associated with IFF reporting. To view the Coalition’s comments, visit https://thecgp.org/images/Comment_IFF.pdf.
Federal Acquisition Circular 2005-66 was released on February 28 which included a summary of the following final and interim rules:
- Definition of Contingency Operation (Interim rule) FAR Case 2013-003
- Changes to Time-and-Materials and Labor-Hour Contracts and Orders (Final rule) FAR Case 2011-025
- Extension of Authority for Use of Simplified Acquisition Procedures for Certain Commercial Items (Final rule) FAR Case 2013-007
- Technical Amendments
Comments on the definition of contingency operation are due April 29, 2013.
“Continuing the Dialogue”
PBS Acquisition Focus for 2013
Dorothy Robyn, Commissioner, GSA Public Buildings Service
Thursday, March 28, Offices of Mayer Brown, 1999 K St, NW, Washington DC
Registration at 7:30am, Presentation and Discussion at 8:00am
Join the conversation as we delve into the PBS acquisition focus for 2013 with PBS Commissioner, Dorothy Robyn. As PBS Commissioner, Dr. Robyn leads one of the largest and most diversified public real estate organizations in the world. The Public Buildings Service is responsible for providing superior workplaces for federal customer agencies at good value for the American taxpayer.
Dr. Robyn manages the nationwide asset management, design, construction, leasing, building management and disposal of approximately 375 million square feet of government-owned and leased space, accommodating over 1 million federal workers, and covering all 50 states, six U.S. territories and the District of Columbia. Additionally, Dr. Robyn oversees an annual budget of more than $9.4 billion and a workforce of almost 6,800.
Attend this session to see how PBS priorities and initiatives will impact sales of products and services to Federal customers. For more details and to register, please contact Athena Oliff at email@example.com.
Registration is now open for the Coalition’s Spring Training Conference on April 17th 2013 at the Crystal Gateway Marriott. Attendees will engage in a government-industry “Myth-busters” dialogue with acquisition leadership from the Department of Defense, Department of Veterans Affairs, General Services Administration and others about key procurement issues that impact members’ government business. The focus on “strategic acquisition” at this year’s conference is in response to increased interest in federal strategic sourcing. Strategic Acquisition can both improve the efficiency of government and provide an opportunity for businesses to offer innovative solutions that help agencies meet this goal. We have developed a robust and informative agenda with early speaker confirmation from Government and industry leaders alike. This is a conference you will not want to miss! Register Here!
Mark your calendars for a new webinar! Join the Coalition and McKenna Long & Aldridge LLP for a one hour lunchtime webinar at 12:30 pm on Foreign Acquisition and the Trade Agreements Act. Register here! If you would like more information, please contact Athena Oliff at firstname.lastname@example.org or 202-315-1052.
The Coalition is establishing a Strategic Acquisition Working Group to make recommendations to the government about how to increase efficiencies in federal procurement and eliminate unnecessary cost drivers in the procurement system. As new Federal strategic sourcing solutions are being developed, this is a wonderful opportunity to share best commercial practices with GSA and OMB. More details will be discussed with members in the committee meetings this month. If you are interested in learning more or would like to volunteer, please contact Aubrey Woolley at email@example.com.