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Federal Times Blog on OS3 and Contract Duplication

For this week’s comment I wanted to share with you a blog post first published on the Federal Times’ Acquisition Blog (www.federaltimes.com). The post highlights GSA’s recent Federal Strategic Sourcing Initiative (FSSI) Office Supply 3 (OS3) and contract duplication. 

GSA increases contract duplication one solicitation at a time

A little over two weeks ago GSA awarded the Federal Strategic Sourcing Initiative (FSSI) Office Supply 3 (OS3) Indefinite-Quantity-Indefinite Delivery (IDIQ) contracts—the third generation FSSI for office supplies. These new OS3 IDIQ contracts duplicate the current GSA Schedule 75 for office supplies—so much so that the OS3 solicitation used GSA Schedule 75 pricing as a benchmark. Moreover, for those GSA Schedule 75 contractors who now have OS3 contracts—the OS3 contract terms require pricing consistency across both vehicles, essentially incorporating by reference the operative GSA Schedule 75 contract terms!

As a result of this effort, GSA and the firms competing OS3 together spent millions of bid and proposal dollars for a duplicative contract vehicle. Time and money could have been saved through the competitive establishment of BPAs under the GSA Schedule 75. More importantly, task order competitions using the GSA Schedule 75 would have leveraged individual agency requirements in a cost effective and efficient manner.

Now comes the latest effort in contract duplication, GSA’s new solicitation seeking a set of commercial office furniture IDIQ contracts for the Total Workplace Furniture and Information Technology (FIT) program. The FIT program is GSA’s new offering to customer agencies to minimize initial capital investments for furniture and IT. Through FIT, GSA will offer customer agencies an installment program to spread the cost of the furniture purchase over a five-year period. The FIT solicitation includes five functional areas covering commercial workplace furniture, tables, high density and rotary filing, seating and demountable walls. Functional Area 1 provides for multiple awards. Functional Areas 2-5 are single-award.

The parallels between the FIT solicitation and GSA Schedule 71 for commercial office furniture are striking. They cover the same types of commercial office furniture. They both establish IDIQ contracts with a $2,500 guaranteed minimum (the FIT solicitation provides a $2,500 minimum for each functional area).

They both use FAR Part 12 commercial item provisions and clauses. As IDIQ contracts, they are both designed to meet agency specific commercial office furniture requirements at the task order level—specific agency requirements that are unknown at the time of award.

If these parallels were not enough, the FIT solicitation goes a step further and makes GSA Schedule 71 pricing a benchmark stating in part that “Pricing Forms must be equal to or less than the price for the same offering on the Offeror’s current Schedule after discounting for any GSA or other Government fee such as the 0.75% GSA fee.”

GSA cannot have it both ways. GSA complains about agencies creating their own contract vehicles that duplicate GSA’s governmentwide contract vehicles, when it is doing the very same thing. It is disheartening. Rather than expending significant time, talent and taxpayer dollars on creating duplicative contract vehicles; GSA can and should improve the efficiency and effectiveness for the acquisition of commercial products and services under the GSA schedules program. It is time to make a good commercial products and services schedules program great.

Finally, and most troubling, is GSA’s decision that Functional Areas 2-5 should be single-award. Under the FIT solicitation, the subsequent agency specific requirements for Functional Areas 2-5 are unknown and unarticulated over the potential five-year life of the single award contracts. As such, the contracts for each Functional Area will result in de-facto sole source procurements for each subsequent task order issued over the life of the contracts. This makes no business or procurement sense for customer agencies or the American people. Competition for agency specific requirements is vital to achieving best value for customer agencies. There is an alternative. GSA Schedule 71 contractors stand ready each and every day to compete, like they do in the commercial market, for the very agency specific requirements that GSA will be “sole sourcing” under the FIT solicitation.

Roger Waldron

President

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