The Coalition welcomes the FSSI OS2 Dashboard as a positive step in improving transparency. The dashboard responds to public requests for more information regarding OS2 including information about pricing, savings and small business participation.
The dashboard states that “[i]n 9 out of 10 cases, the median OS2 price is lower than the median Schedule 75 (Non-OS2).” The dashboard also provides a pricing table, “April 2014 Price Comparison: Schedule 75 to OS2,” that allows for a comparison of median Schedule 75 prices to median OS2 prices on an item by item basis. The dashboard can be found here.
The pricing information contained on the dashboard is instructive regarding the shortcomings of FSSI. That 9 out 10 times the median OS2 prices of an item is lower than the median Schedule 75 is unremarkable! The schedule contracting process is designed to lower prices by competition at the task order stage. The dashboard’s pricing comparison information confirms the competitive nature of the schedules ordering process—not the efficacy of the current FSSI. Individual agencies competing specific requirements can and have achieved similar, if not superior savings. In fact, our members have experienced situations where agency specific BPAs have provided a better deal, including lower prices, than the FSSI OS2 BPAs only to see the agency move to the OS2 BPAs rather than maintaining their own.
The current FSSI approach reflects a vision of GSA as “America’s Buyer.” The Federal Acquisition Service (FAS) has described current FSSI strategy as “supplier suppression,” the key tenants of which are limiting the number of suppliers, increasing data reporting requirements and driving down pricing through generic government-wide BPAs. This approach limits competition, hurts small businesses and reduces access to the commercial marketplace.
Sound procurement outcomes are built upon clear, consistent and firm requirements. Moreover, each agency/department is in the best position to understand, articulate, procure and manage its requirements and mission needs in the procurement process. That is why the Coalition, with input from the procurement community, has set forth a list of “Best Practices for Establishing Blanket Purchase Agreements.” Chief among the best practices is focusing on requirements—and that BPAs reflecting single agency requirements should be preferred over multiple agency or government-wide BPAs. Single agency BPAs allow the government to state specific, realistic, authentic requirements that can be accurately priced. In contrast, GSA’s generic government-wide BPAs cannot articulate specific, realistic, and authentic requirements through FSSI. Simply put GSA does not hold or manage other agency requirements. As such, the current FSSI approach creates detachment between contractors and customer agencies that reduces value and customer satisfaction.
The irony is that the GSA Schedules contract structure, ordering procedures, and electronic tools are all designed to drive competition for agency specific requirements. As a refresher, here are the key features of the program:
- Statutory and regulatory mandates for streamlined task and delivery competition
- GSA Advantage! serves as a market research tool providing customers and contractors with pricing and other key information for products and services on contract
- E-buy, GSA’s electronic quote tool, increases transparency and competition by allowing customer agencies to post RFQs and conduct task and delivery competitions consistent with statute and regulation
- Continuous open seasons that provide the opportunity for commercial firms to submit new offers for commercial products and services every working day of the year
The top down, lowest common denominator approach to FSSI does not reflect the federal marketplace. At its best, GSA is not America’s Buyer, rather it is the Federal Government’s Procurement Market Maker. GSA brings customer agencies and commercial firms together via the GSA Schedules to compete, acquire and deliver best value outcomes for the America people.
The FSSI check the engine light is on and it is time for a tune up!
Roger Waldron
President