In leading GSA’s Federal Acquisition Service (FAS), Commissioner Sonny Hashmi has established “North Star Goals” for the organization in its efforts to support customer agency missions on behalf of the American people. North Star Goals are generally long-term, stretch goals. They are aspirational, yet achievable, and comprise multiple projects. The following diagram, part of a recent FAS slide presentation, sets forth FAS’s North Star goals:
“Make it dead easy to do business with FAS” is at the center of this diagram, reflecting the central force driving FAS’s success in supporting customer agency missions on behalf of the American people. “Creating tremendous value for our customers” and “…a thriving, innovative, compliant[,] and equitable marketplace” are fundamentally dependent on making it “dead easy” to do business with FAS for both customer agencies and industry partners. As often has been observed, the GSA FAS, customer agencies, and industry are like a three-legged stool, each dependent on the other to support agency missions.
In this context, GSA FAS is the channel, or market maker, through which customer agencies and industry partners engage to support and deliver mission requirements. So, how do we work together to make it dead easy to do business with FAS and within the FAS marketplace? Here are several “pathways” to FAS’ North Star Goals:
- Right off the launchpad, delete the “highly competitive” language from the MAS solicitation, as discussed in last week’s blog. This language is undefined and introduces confusion into the procurement process. As such, it represents a significant barrier to entry for commercial firms, especially new small businesses seeking to enter the federal market through the Multiple Award Schedule (MAS) program.
- Allow for automatic price reductions when submitted by current MAS contractors. Doing so immediately delivers value to customer agencies.
- Publicize all internal FAS policy guidance relied upon by contracting operations. Transparency is fundamental to understanding FAS procurement priorities and program considerations. The more information industry partners have regarding how FAS approaches the market, the better industry can meet FAS and customer needs, improving the efficiency of the procurement process. This information was once regularly published by FAS and the practice should be revived.
- Incorporate associated material terms and conditions for pricing in the 4P tool. This pathway would ensure a rational, fair conversation/negotiation of price consistent with regulation and the market.
- Lower the Maximum Order Threshold to $250,000 across the program to reduce burdensome record-keeping; bring MAS contract terms in line with FAR 8.4; and enhance the ability to provide solutions, rather than individual SINs, in response to agency requirements.
- Expand the e-commerce program for customer agencies and industry partners, including small businesses.
- Continue to modernize GSA’s e-systems including the transition to the FAS Catalog Platform for all MAS contractors.
- Reform cloud pricing on MAS contracts to allow greater variability consistent with the commercial cloud marketplace. Recognizing the dynamic nature of the cloud marketplace, remove the Price Reduction Clause (PRC) for cloud services.
- Remove the PRC for all services requiring a Statement of Work (SOW). The unique nature of each SOW completely undermines any underlying rationale for, and applicability of, the PRC.
- Make the EPA clause changes permanent to improve the response to, and reflect, the commercial market.
- Reverse the decision not to implement Section 876 for MAS service contracts.
- Commit to, and execute on, holding an in-person FAST 2024 Training Conference, where customer agencies, FAS, and industry attend procurement training, program presentations and updates, and engage in cross-cutting market research.
- Require that when a FAS contracting officer cites certain data as support for a negotiation position vis-a-vis an offeror or contractor, that data be made available to the offeror or contractor, in order provide a fulsome, reasonable discussion of negotiation positions with the goal of obtaining a reasonable outcome for all stakeholders.
These pathways will help FAS reach its North Star Goal of making it “dead easy to do business with FAS.” In achieving this threshold goal, FAS will be able to deliver on “creating tremendous value for our customer agencies” and “creating a thriving, innovative, compliant[,] and equitable marketplace.”
We ask you: What are your ideas for making it dead easy to do business with FAS? The FAR and Beyond blog wants to hear from you. So, please submit your comments here.
And for FAS contractors, please do respond to FAS’s annual customer survey, which can found here.