Skip to Content

Knowing the Unknowns: Avoiding Unintended Consequences

Welcome back, and Happy New Year! The Coalition hopes everyone had a restful, healthy, and happy Holiday Season. As we begin 2019, the Coalition would to thank its members, as well the many acquisition professionals from across the procurement community, for their strong support and active engagement throughout 2018. Everyone’s efforts here are key to continuing the dialogue on our shared goal of improving the Federal procurement system.

In 2018, much of the conversation focused on the General Services Administration’s (GSA) implementation of implementation of Section 846 of the Fiscal Year (FY) 2018 National Defense Authorization Act (NDAA). Indeed, just before the holidays, GSA hosted a Federal Marketplace Industry Day to discuss its ongoing implementation efforts related to Section 846. Notably, during the event, GSA Administrator, Emily Murphy, remarked:

As I share my vision today for the Federal Marketplace, I want to make one point. One of the biggest risks to any transformative effort and especially in procurement is the unknown unknowns and we have got a lot of expertise here in this room. I want to really encourage you, if you see one of those unknown unknowns, speak up. Raise your hand. Talk to us about it.

Accordingly, with the new year upon us, the Coalition is providing its, “Unknown Unknowns,” also known as unintended consequences, to assist GSA in its efforts to develop a “common sense” e-Commerce solution for Federal customers, industry stakeholders, and the American people.

Much like the Coalition has done in the past, each of these unintended consequences will be addressed in more depth through subsequent FAR & Beyond blogs in the coming weeks. So, without further ado, here are some of the Coalition’s Unknown Unknowns:

  • Promoting Competition for GSA’s Proof of Concept. By limiting the pilot to only one type of commercial e-Commerce business model, aside from conflicting with the language and spirit of the law, GSA’s current approach unduly restricts competition and places GSA and, perhaps, the limited number of its pilot vendors, in the position of determining winners and losers, rather than the market itself.
  • Addressing Cybersecurity Through Effective Supply Chain Risk Management. It is unclear whether there are any specific requirements or restrictions in place to address cyber and supply chain risks, such as a limitation on the types or categories of products available for purchase, under the pilot.
  • Streamlining Pre-Existing Contract Programs. It is not clear how GSA will address the pilot’s impact on existing programs and initiatives, such as the Schedules Consolidation effort?
  • Ensuring Marketplace Integrity. There are potential organizational and other conflict of interest issues that could be attendant to the e-Commerce pilot and should be clearly addressed to avoid unintended negative outcomes.

The Coalition looks forward to a robust dialogue with all stakeholders on each of these unintended consequences, as well as others, in the coming weeks. To this end, we will provide a discussion of the foregoing issues in order to spark conversation around solutions that benefit all stakeholders in the procurement process. Stay tuned.

Back to top