This week the Coalition provided Defense Procurement and Acquisition Policy (DPAP) with “Myth-Busters” feedback regarding the policies, goals and objectives for Economy Act and non-Economy Act Interagency Acquisitions. Our feedback can be found here. As you know, DPAP is currently conducting a review of the rules and regulations governing interagency acquisition acquisitions across the Department. A review that was prompted by recent statutory and regulatory changes to an already complex labyrinth of rules governing interagency acquisitions. As currently structured, the complex rules governing interagency acquisitions make it unnecessarily difficult for customer agencies to leverage pre-existing government-wide contract vehicles and assisted services organizations to support mission needs.
For example the regulatory language at Federal Acquisition Regulation (FAR) 17.502-1 requires a written “determination of best procurement approach” by a customer agency prior to utilizing another agency to conduct an acquisition on its behalf (i.e. assisted services) and/or prior to placing an order against another agency’s IDIQ contract (includes all GWACs orders and MAC orders regardless of dollar value as well as Federal Supply Schedules (FSS) orders exceeding $500,000). There is no similar requirement for open market procurements. As such, the requirement for a “best procurement approach” determination for interagency acquisition creates a presumption in favor of open market procurements that fosters unnecessary contract duplication. Contract duplication increases costs to customer agencies, contractors and ultimately the American taxpayer. Duplicative open market contracts also dilute the government’s buying power. Rebalancing FAR 17.502-1 to eliminate the presumption in favor of open market procurements is a great opportunity to reduce unnecessary contract duplication.
DPAP is to be commended for embarking on a review of the policies, procedures and rules governing the Department’s interagency acquisitions. The Coalition’s feedback focuses on reducing unnecessary procedural burdens and streamlining the decision making process when using interagency acquisitions. Government-wide contracting vehicles like the FSS program and the IT GWACs save time and money by providing a common platform for customer agencies to effectively compete and acquire solutions, services, and products to support mission needs. Our feedback to DPAP regarding interagency acquisition is part of a continuing “Myth-Busters” dialogue with stakeholders across the procurement community. It is a dialogue that seeks to improve the efficiency and effectiveness of the procurement system.
To that end, the Coalition has developed a list of “Government Procurement Practices that Add Costs without Enhancing Value.” The list can be found here. The list is a living document! We look forward to your feedback and comments regarding the list as well as real examples of practices that increase costs without additional value. Your feedback, comments and examples can be provided to me at firstname.lastname@example.org. We will use your input to periodically update and share the list across the procurement community. Our goal is to foster a focused conversation that leads to improved procurement practices that save time, money and resources for government, the American people and contractors.
We look forward to your feedback!