During the Coalition’s recent Fall Training Conference there were many discussions regarding the pace of MAS purchases. It was widely communicated that MAS purchases leveled off from previous year declines and were growing slightly (approximately 1%) as we enter the new fiscal year. That is good news for government-wide contracting, customer agencies, and MAS contractors. The MAS program remains the largest commercial item contracting program across government. It is strategically positioned to efficiently and effectively deliver best value commercial solutions, services and products to meet customer agency missions. The MAS program’s potential remains vast!
As Administrator Denise Turner Roth noted in her recent interview with Federal Times, if GSA offers contracts (e.g. MAS contracts) that are effectively structured to meet customer needs, then agencies will not create their own contract vehicles. How can GSA better meet customer needs through the MAS program? In short, how can GSA “grow” the MAS program? Here are three key reforms that will improve the efficiency and effectiveness of the MAS program:
No. 1. Implement Other Direct Costs (ODCs) on MAS contracts.
“ODCs” are a FAR-sanctioned, contracting mechanism to allow reimbursement for materials, other direct costs and indirect costs on commercial item contracts. ODCs provide the contract flexibility to efficiently and effectively meet customer agency mission requirements for comprehensive commercial service solutions. Yet, although the operable FAR-sanctioned provision currently resides in MAS contracts, ODCs are prohibited under MAS contracts. ODCs are a game changer. GSA has already made great strides in consolidating the Professional Services Schedules (PSS). ODCs would significantly enhance the PSS’s ability to meet customer agencies cross-cutting professional services requirements. Our members report that customer agencies often turn away from the MAS program due to the lack of ODC functionality. As a result, customer agencies are creating their own duplicative contract vehicles. Ironically, GSA’s GWAC’s include ODCs! The time is now for implementing ODCs to meet customer needs and grow the MAS program! Take a look at the Coalition ODC White Paper for more on implementation.
No. 2. Reform the MAS Pricing Policy.
The decades-old pricing policies governing the MAS program reduce competition, limit access to innovation, and increase costs for government and industry. MAS contractors report that they will not add new technologies/capabilities in the face of the compliance risk associated with the Price Reduction Clause (PRC). Moreover, as the commercial market continues to evolve towards even greater use of flexible pricing methodologies, the current static MAS pricing model based on the Commercial Sales Practices (CSP) submission requirements and PRC fails to provide customer agencies with best value mission support from the commercial marketplace. Take a look at the Coalition’s white paper on MAS pricing for more on this issue.
No. 3. Improve MAS Blanket Purchase Agreements (BPAs).
The current regulatory regime creates a strong preference for multiple award BPAs. The regulations need to be simplified. Agencies should be empowered to identify and compete recurring requirements for single award BPAs. These single award BPAs should include firm volume commitments for agency requirements. Single award BPAs may be the greatest untapped resource for agencies seeking to leverage and compete their requirements under the MAS program. In addition, reforms should be made to allow BPAs to extend beyond the term of the underlying contract. This reform would create greater certainty in the competitive MAS market for both customer agencies and MAS contractors. Certainty that will enhance customer satisfaction and increase use of the MAS program. To its credit, FAS is addressing evergreen contracting in a holistic manner through reforms in the submission of follow-on offers for contractors reaching the end of the 20 year contract term. The next vital step is to address the term of competed BPAs under the MAS program!
These three key reforms can further unleash the power of the MAS program to bring best value commercial solutions, services and products to customer agencies. GSA has the authority and the discretion to accomplish these reforms and the Coalition stands ready to work towards our common goal of improving the MAS program.