Over the past few weeks, the Coalition for Government Procurement has been keeping pace with the dynamic changes underway in the federal market. We have held key inaugural meetings, responded to a number of critical requests for comment, and scheduled important industry events. Still, between now and the end of the year, there is more work to do. Set forth below is a run-down of what the Coalition has done, as well as a look at what we are doing to close out the year.
Inaugural Meeting of the Cyber and Supply Chain Security Committee – At the end of September, the Coalition hosted its first Cyber and Supply Chain Security Committee meeting. The guest panelists were Katie Arrington, Chief Information Security Officer for the Office of the Under Secretary of Defense for Acquisition; Joyce Corell, Assistant Director, Supply Chain and Cyber Directorate, National Counterintelligence and Security Center, Office of the Director of National Intelligence; and Ben Richardson, Acting Director, Industrial Security Integration & Application, at DCSA. All were generous with their time as they provided deep substance on DoD’s efforts to leverage the Capability Maturity Model Integration (CMMI) model and to establish standards for a Cybersecurity Maturity Model Certification (CMMC). They also addressed questions regarding the impact of CMMC on acquisition. Their talk was followed by Townsend Bourne of the Sheppard Mullin law firm who led a discussion of these issues for members.
Inaugural Meeting of the Business and Regulatory Issues Committee – The Coalition kicked-off another first, its Business and Regulatory Issues Committee or “BRIC,” providing an education channel for stakeholders operating in the Federal market space. Through the BRIC, these stakeholders are afforded an opportunity to share their expert perspectives on cross-cutting issues in their respective ecosystems, thereby promoting understanding that will translate into improved business and agency mission performance. The committee’s first guest speaker was one of the leading policy experts in Government Procurement, Jon Etherton, President of Etherton & Associates, who provided a legislative and policy update and forecast for the remainder of the calendar year.
Regulatory Comments and Correspondence – In response to a very busy regulatory season, the Coalition filed comments in response to multiple Government announcements. Among other things:
– The Coalition filed comments on GSA’s review of the information collection requirements for Transactional Data Reporting (TDR) expressing concerns that the Government already possesses the data that it is requesting through TDR, and that vendors electing to comply with TDR not be compelled to comply with the Price Reduction Clause (PRC) and Commercial Sales Practices (CSP) compliance process. The Coalition recommended that TDR be an option for all Schedule holders in place of PRC compliance and submission of the CSP.
– At the same time, the Coalition also commented on GSA’s review of the information collection requirements for the Commercial Sales Practices (CSP) disclosures and the Price Reductions Clause (PRC). We noted that the PRC serves as a restraint of trade, fundamentally limiting the ability of Schedules contractors to compete in the private sector and operating to increase prices and operational costs while hindering innovation and competition in the commercial market. The Coalition recommended that GSA should eliminate the PRC and reform the CSP to permit flexibility in reporting.
– We raised cost recovery concerns related to GSA’s bilateral Schedules modification to facilitate implementation of the Interim Rule concerning representations and prohibitions in connection with providing certain telecommunications and video surveillance services or equipment (Section 889).
– We also responded to the interim rule itself, with comments regarding specificity in connection with definitions, processes, and reasonable reliance on subcontract provisions and subcontractor representations; the need to address the application of the rule for e-commerce pilots; cost recovery; and the need to address onerous reporting timeframes.
– In response to GSA’s Commercial Platform Initiative (CPI) solicitation, the Coalition filed questions; inquired the DoJ and the FTC whether they could opine on e-commerce in the federal space; and asked whether the USTR could share his views on federal e-commerce from the standpoint of trade.
Launched the Tuesday Tracker – In still another first, the Coalition launched its Tuesday Tracker a new newsletter, which provides links to current front burner and Congressional articles, key agency reports, and an updated tracker of FAR/DFARS regulatory changes.
Small Business Committee – In conjunction with the law firm of Holland & Knight, the Coalition’s Small Business Committee hosted a discussion, “Acquisition Innovation Essentials,” a law and policy primer on Other Transactions (OT) tools presented by Ben McMartin, Chief of Acquisition Management Office at the US Army Combat Capabilities Development Command Ground Vehicle Systems Center.
Major Upcoming Events – Between now and Thanksgiving, the Coalition will be preparing several key events:
– Healthcare Committee members will be joining the Coalition for its annual meeting with the VA National Acquisition Center (NAC) in Chicago on October 22. We thank Baker Tilly for offering its facilities and joining us in hosting this meeting. Both the VA Federal Supply Schedules and the National Contract Service programs will participate in the government and industry dialogue on issues including the NAC’s priorities and initiatives, and potential reforms to the VA FSS program. The Coalition is excited to announce that this will be the first year where the National Contract Service participates in this meeting. Members must RSVP to attend, and they may do so by emailing Michael Hanafin at firstname.lastname@example.org.
– On November 20, we will be hosting our Fall Healthcare Procurement Training Conference, “DHA, DLA, and VA – A Team Approach,” at the Fairview Park Marriott, Falls Church, VA. This all-day conference will feature key leaders from those agencies addressing topics, including VA Healthcare Acquisition, Clinical Input, Medical Imaging Equipment, Medical Surgical, Pharmaceutical; Medical Supply Chain, and Clinical Evaluation. Upwards of 15 Government speakers will be available for afternoon breakout sessions. Background and registration information on this event can be found here.
– In the evening on November 20, the Coalition will host its Excellence in Partnership (EIP) Awards Dinner, also at Fairview Park Marriott, Falls Church, VA. The EIP honors individuals and organizations in the acquisition community who have made significant contributions to the procurement system that deliver best value and meet agency missions. Our keynote speaker for the evening will be Catch Me If You Can author Frank Abagnale, one of the world’s top fraud prevention experts, who will share his critical lessons from the world of security, helping business and government organizations stay a step ahead of the criminals. Prior to Mr. Abagnale’s talk, we will have the pleasure of hearing from Emily Murphy, Administrator, GSA. You can register for the event here.
– Last, but certainly not least, the Coalition will hold its Fall Training Conference, “Commercial Acquisition Disruptors: e-Commerce, Consolidation, and Cyber,” on November 21, at the Fairview Park Marriott, Falls Church, VA. Procurement experts from Government and industry will present on topics including Schedules Consolidation; Transactional Data Reporting; E-commerce, CICA, and the Future of Competition; and the Future of the Supply Chain. Also, we will dialog with GSA Administrator Emily Murphy, and we will hear from Major General Cameron Holt, Deputy Assistant Secretary for Contracting, USAF, on Bringing Innovation to the Procurement System. Afternoon breakout sessions will feature the option to select among eight different sessions and hear from nearly 25 government officials discussing IT; Services; Product Centers; Assisted Services; GWACs; GSA Systems; FedMall; and Cyber. Background and registration information on this event can be found here.
The Coalition’s work for the year is far from finished. As we enter the holiday season, members will be receiving information about our next undertaking. The Coalition, like others in the Federal space, is approaching a crossroads, assessing new opportunities to represent the consensus interests of its members. One issue we will be addressing is the establishment of advocacy activities under the umbrella of the association. Please keep an eye out for details, and, in the meantime, rest assured that the Coalition remains hard at work supporting its members.