On April 6th, GSA Administrator Denise Turner Roth launched the ”Making it Easier” (MIE) campaign, a series of new contracting initiatives designed to streamline and simply the Federal Supply Schedule (FSS) proposal submission and evaluation process. In particular, MIE focuses on making “it easier for new and innovative companies to [join those existing innovative firms that] do business with the government.” MIE’s current initiatives include:
- FASt Lane which seeks to cut from 110 days to 45 days the time it takes for new vendors to be placed on the FSS schedule and reduce the time to modify existing contracts to one or two business days.
- IT Schedule 70 Startup Springboard to provide an alternative to the 2-year corporate experience requirement for qualified new businesses.
- Schedule 70 Plain Language Roadmap which is a new site that provides a clear and concise path to help users navigate the offer submission process.
- MAS Welcome Package to greet new vendors with clear information regarding the FSS contracts/program, eliminating inconsistent messaging and outdated guidance.
These four initiatives reflect a renewed focus on streamlining and simplifying the FSS contracting process. The Coalition welcomes and supports such common sense efforts to improve the FSS program experience, and it applauds the Administrator’s efforts. In the spirit of the MIE campaign, just this week, the Coalition issued a MAS Checkup Survey to our members seeking an updated feedback/assessment of the processes, procedures, and regulations governing the FSS program. For example, among its survey questions are:
- What are the top 3 government-unique regulations that increase costs for your company?
- Have the GSA schedules become more or less similar to the commercial market over the last five years, and why?
Consistent with its commitment to serve the contracting community, the Coalition intends to share the results of this survey with key stakeholders across the federal procurement system.
MIE is a positive step in recognizing, addressing, and implementing common sense FSS reforms, and the Coalition looks forward to working with GSA as the implementation of the forgoing initiatives continues. At the same time, a significant opportunity remains for GSA to reform the FSS program and enhance the delivery of best value commercial products, services, and solutions to customer agencies and the American people. The long-standing consensus among stakeholders is that the FSS program needs to address its outdated contract pricing policies, eliminate the Price Reduction Clause (PRC), and include “Other Direct Costs”(ODCs) in FSS contracts. These reforms will have a profound, positive impact, improving the efficiency and effectiveness of the FSS program. Just as importantly, these reforms will reduce costly administrative and compliance burdens, while promoting the implementation of innovative, commercial solutions across the FSS program.
With regard to FSS’s pricing policies, this week GSA issued a second public notice in which it solicited additional comments on the burdens of the” Federal Supply Schedule Pricing Disclosures.” Essentially, the public notice seeks information regarding the paperwork burdens associated with the Commercial Sales Practices (CSP) Format and the PRC, and it is especially significant to the Coalition because it is based on the Coalition’s January 2016 comments on the FSS Pricing Disclosures. The due date for comments is May 11th, and the Coalition looks forward to member feedback as it prepares its response.
Submitting comments to GSA makes a difference!
In a 2011 public notice, GSA estimated the total annual burden of the PRC to be 9,000 hours for the entire MAS program. In response to comments the Coalition submitted, that estimate was revised to 868,920 hours, an increase of over 9,000 percent. GSA also noted in its public notice that the Coalition’s comments were “insightful and provid[ed] a foundation on which to counter-estimate annual burden hours.” As a result of these comments, stakeholders across the procurement community received an enhanced substantive understanding of the burdens associated with the current FSS pricing disclosures, and the case for reform of the FSS pricing policies was strengthened. The Coalition appreciates the continuing opportunity to work with GSA on MIE to reform the FSS pricing policies, align the program with the commercial market, and deliver best value for customer agencies and the American people.
A final thought on ODCs
It is important to remember that GSA has both the authority and the channel through which to incorporate ODC capability into FSS contracts. Specifically, GSA’s governing statutes provide it with the authority to establish policies and procedures for the FSS program. Further, to the extent that GSA believes regulatory adjustments are the way forward for ODCs, the General Services Acquisition Regulation (GSAR) provides a platform for implementation. As always, the Coalition stands ready to work with GSA on this effort.
Next week, FAR and Beyond will provide more thoughts on FSS reform—what ever happened to the “unpriced” Schedule concept?