The questions surrounding NS2020’s Enterprise Infrastructure Solutions (EIS) procurement. EIS is the Federal Acquisition Service’s (FAS’s) follow-on telecommunications procurement that will replace the current Networx contracts. In April, 2014, FAS’s Integrated Technology Service (ITS) published a white paper outlining “The Network Services 2020 Strategy entitled NS2020: Defining the future of Federal telecommunications.” This past February ITS issued the DRAFT Enterprise Infrastructure Solutions (EIS) Request for Proposals (the draft RFP) seeking public comment.
A key aspect of EIS is its expanded scope of work which includes telecommunications services and other IT services. The layout of Section B of the draft RFP is instructive. It includes six mandatory telecommunications-based Contract Line Items (CLINs). These mandatory CLINs must be proposed and acceptable to the Government in order to be eligible for award. In addition, Section B includes over 25 optional CLINs covering a host of other services. Included among the optional CLINs are Data Center services and Cloud services. The optional Cloud services include: (1) Infrastructure as a Service; (2) Platform as a service; (3) Software as a service; and (4) Content Delivery Network Service. The broad scope of EIS combined with the narrow entry point (i.e. the mandatory telecommunications CLINS) has raised questions regarding contract duplication, the role of IT GWACs and the impact of competition across the Federal IT marketplace.
The Clinger-Cohen Act of 1996 provides in part that GSA “shall continue to manage the FTS 2000 program, and to coordinate the follow-on to that program, for and with the advice of the heads of executive agencies.” GSA has operated the FTS 2000 and its follow-on telecommunications programs pursuant to this separate authority. At the same time, the Clinger-Cohen Act repealed GSA’s exclusive government-wide authority for the acquisition of IT while providing the Office of Management and Budget (OMB) with the authority to designate agencies/departments as executive agents for the government-wide acquisition of IT.
Consistent with the Clinger-Cohen Act, GSA has operated its portfolio government-wide IT contracts (currently Alliant, Alliant SB, 8(a) Stars, and VETS) pursuant to a designation from OMB. These contracts are commonly referred to as IT GWACs. NASA SEWP and NIH’s CIO- SP3, CIO-SP3 SB, and CIO-CS are also IT GWACs operating pursuant to a designation from OMB. These IT GWACs include cloud services and data center services as well as other IT services. The “blurring of lines” between the IT GWACs and EIS, raises the following questions:
- As a threshold matter, is the broad EIS contract structure consistent with the underlying statutory authority for the GSA’s telecommunications programs?
- Should ITS seek an executive agent designation for EIS for the IT services portion of the contract vehicle?
- Has ITS or OMB assessed or reviewed the potential impact of EIS on the current IT GWACs?
- Has ITS assessed the potential impact on IT Schedule 70?
- How will ITS manage the EIS contracts to ensure bundling of cloud and/or data center services does not reduce competition for such services across the entire portfolio of IT GWACs?
- Will OMB consider authorizing or including telecommunications services as part of the scope of the IT GWACs?
- Should IT Schedule 70 include a full suite of telecommunications services?
Throughout the acquisition planning process for EIS GSA demonstrated a willingness to engage in a Myth-Busters dialogue with all stakeholders. The Coalition commends GSA for its commitment to a dialogue on EIS and we look forward to working with all stakeholders to address the uncertainty surrounding the role of NS2020, the IT GWACs and IT Schedule 70. Most recently, in April the ITS team had an industry day and participated in a Myth-Busters breakout session at the Coalition Spring Conference.
The Myth-Busters dialogue will continue on June 16th as the Coalition’s GWAC, MAC and Enterprise Contracting and IT/Services Committees will host Mary Davie, ITS Assistant Commissioner and her team for a Myth-Busters discussion.