This week, GSA posted the signed Delegation of Authority/Assignment of Function agreement (the delegation) for the Department of Veterans Affairs (VA) to continue its management and operation of the healthcare-related Federal Supply Schedules (FSS). The executed delegation addressed the Government Accountability Office (GAO) Report, VA Acquisition Management, Steps Need to Ensure Healthcare Federal Supply Schedules Remain Useful, (GAO-20-132). That report set forth 11 GAO recommendations to improve VA FSS program management, the timeliness of contract awards, understanding of the needs of users, and contracting staff training.
The Delegation
The delegation provides VA with the authority to operate and manage the healthcare FSS. The healthcare FSS includes Federal Supply Group (FSG) 65 – Medical, Dental, and Veterinary Equipment and Supplies; FSG 66 – Instruments and Laboratory Equipment; Federal Supply Classification (FSC) J065 – Maintenance, Repair, and Rebuilding of Equipment – Medical, Dental and Veterinary Supply; FSC Q301 – Medical, Laboratory Testing; and FSC Q999 – Medical, Other (including 621-1 Temp Healthcare Staffing Services). Under the delegation, the VA is responsible for internal oversight of the healthcare FSS to ensure compliance with all applicable laws and regulations, including VA specific VA FSS policies and procedures.
As noted in the delegation, GSA retains the authority to issue regulations and establish policies and procedures governing and generally applicable to the FSS program. The VA will be provided the opportunity to review and comment on all proposed or revised FSS policies and procedures applicable/related to the operation and management of the healthcare FSS. The VA can make improvements to the healthcare FSS so long as the improvements do not conflict with the laws, regulations, policies, and procedures generally governing the FSS program.
The Next Steps in the GSA-VA Partnership
The delegation strikes the right balance between GSA’s overall authority for the FSS program and the VA’s specific operational and management responsibilities for healthcare FSS. The delegation’s framework provides a strong foundation for collaboration between GSA and the VA. Significantly, GSA and the VA already are working together to bring improvements to the healthcare FSS. In fact, engagement between the two agencies is at the highest level in decades, with ongoing, periodic meetings focused on the FSS program and the Federal Acquisition Service’s (FAS’s) role in supporting VA operations.
GSA and the VA are in the process of establishing an interagency agreement (IA) that will allow the VA to leverage GSA’s electronic systems (e.g., e-offer, e-mod) for the healthcare FSS. The IA is timely. As GSA invests in, and implements, the next generation of electronic systems for the overall FSS program, the IA will ensure the VA will have access to, and can implement, the next generation electronic systems. Ideally, the IA will also allow the VA to request/include any specific system requirements it may need to support management of healthcare FSS contracts.
This GSA-VA partnership is a significant opportunity, not only for both agencies, but also for the veterans they serve. For instance, the IA addressing electronic systems affords the VA the opportunity to gain insights from GSA’s experiences running government-wide programs. By so doing, it will allow the agencies to collaborate on and harmonize those policies and procedures underlying the VA’s programs, assuring alignment between the two programs. This harmonization will improve the throughput of work, expediting the benefits our veterans receive.
Indeed, the potential of the IA prompts a question whether this collaboration is an opportunity to institute other improvements by expanding GSA-VA engagement beyond the realm of electronic systems into other spheres of activity. Recently, the Coalition discussed concerns about inflation and the impact on government contracting. We stated:
MAS contractors are seeing inflationary cost and pricing pressures across the supply chain, from transportation, to materials, to wages, to energy, and all are prompting the need for price and rate increases. Yet, GSA’s current framework leaves contracting officers relying on a standard Economic Price Adjustment (EPA) clause with little or no effective guidance supporting the streamlined administration of contractor requests for price increases.
One way to mitigate the impact of inflation is to improve the process of government contracting. As noted, improving the implementation of the EPA clause can help, as can improving the use of transactional data. These improvements drive out the wasted time and increased costs associated with process. Reducing process time and costs across the FSS program will help the industrial base trying to manage through our challenging economic times. In a very real sense, streamlining through enhanced collaboration is an inflation mitigation strategy.
Finally, the GSA-VA partnership represents an opportunity for VA, GSA, and contractors to collaborate on the processes and systems that serve veterans. Bringing together all stakeholders expands the knowledge base drawn upon for improving service delivery. It represents a win-win-win for all parties involved.
With its vast membership of companies dedicated to the healthcare of veterans, the Coalition takes great interest in the potential benefits associated with the delegation. We hope to be a facilitator for the dialog between agencies and the private sector to enhance service to the veterans and their families.