With the start of the new fiscal year (FY24), the Federal Acquisition Service (FAS) launched its much-anticipated organizational realignment. The realignment breaks down regional stovepipes across FAS, creating a more customer focused structure to support federal agencies and industry partners serving those agencies. As FAS Commissioner Sonny Hashmi stated in a recent post, “Our regional based employees aren’t going away, but this shift in our structure will meet the growing demand from our customers that FAS respond holistically when it comes to contracting assistance.”
The realignment creates teams focusing on specific agencies, replacing the regional structure that focused on multiple customers within and across separate geographic regions. It also breaks down the long-standing regional contracting structure that supported the MAS program. In its place, the realignment focuses and centralizes MAS contracting management structure for the Office of Information Technology Category, the Office of Professional Services & Human Capital Categories, and the Office of General Supplies and Services Categories.
Breaking down stovepipes across the MAS program and creating teams that focus on specific customers creates an opportunity framework to make it “Dead Easy” for customer agencies and industry partners to do business with FAS. There are several areas where FAS can build on the realignment to make it “Dead Easy.” Here are three:
First, in moving away from the regional reporting structure, FAS can better support MAS contracting operations. A streamlined, centralized management structure will enhance training, guidance, and professional development of the MAS acquisition workforce. It also will provide a more effective framework for managing workload across the MAS program. In turn, this will lead to more consistent and sound negotiation and administration of MAS contracts.
In the past, the regional structure gave rise to differing cultures, negotiation approaches, and interpretations of applicable regulations and solicitation provisions. Creating consistency across the program based on sound application of the rules will increase efficiency and reduce costs for FAS. Correspondingly, it also will increase competition and access to commercial services, solutions, and products by eliminating the significant variations in the application of the key MAS procurement rules across the program, all to the benefits of customer agencies, GSA, and industry partners.
Second, the realignment provides an opportunity to increase transparency for customer agencies and industry partners seeking to do business with FAS. The creation of teams focused on specific agencies will enhance communication and customer support. The new structure also can enhance transparency with regard to guidance impacting the MAS program. For example, in the past, certain guidance documents that directly impact the MAS negotiation process (and MAS contractors) has not been made available for public review. PAP 2021-05, Evaluation of FSS Program Pricing, is one such example. This PAP fundamentally alters the MAS negotiation process, establishing evaluation standards, requirements, and procedures not found in the Federal Acquisition Regulation (FAR) or the General Services Acquisition Regulation (GSAR). Given the significant pricing policy changes outlined in the PAP, it should have been subject to public review and comment. The new FAS structure provides an opportunity to increase transparency through sustained engagement with industry in this important area.
Third, the alignment provides an opportunity to improve data management. FAS and the federal government as a whole are in the midst of a management transition towards data-driven decision making. One example of this transition is the move in the MAS program from CSP to TDR. The use of pricing data in the management/negotiation of MAS contracts has revealed key aspects of the data itself that make it harder for contracting officers and industry partners to reach an understanding as to what is a fair and reasonable price. Data context is critical to data driven decision making. How old is the data? Is the data accurate? What are the associated terms and conditions? What are the current market conditions? Is the data backward looking or is there forward-looking data regarding the market? The questions all go to the integrity of the data being used to assess fair and reasonable pricing. The FAS realignment provides an opportunity to address and improve data integrity and data driven decision making.
There are other framework opportunities to make it “Dead Easy” to do business with FAS. Our Fall Training Conference, What is Fair and Reasonable?, provides a wonderful opportunity to engage with FAS on our shared goals of delivering best value mission support for customer agencies and the American people.
The Fall Training Conference will be held on November 15-16 at the Fairview Park Marriott. We look forward to seeing you all there!