FAR & Beyond: Despite the snow, January has been a very busy month for procurement policy/management issues and initiatives.
Defense Acquisition of Services
On January 6th, the Department of Defense (DoD), Office of the Under Secretary of Defense for Acquisition Technology & Logistics USD (AT&L) published DoDI 5000.74, Defense Acquisition of Services. The new guidance establishes policy, assigns responsibilities and provides direction for the acquisition of services across DoD. The guidance establishes and implements a management structure for the acquisition of contracted services as well as addresses the management and use of data. The guidance seeks to create greater clarity and transparency for DoD and its stakeholders regarding the organizational structure and management approaches for the acquisition of services.
FSS Pricing Disclosures
On January 19th the Coalition submitted its comments on the information collection requirements of the Federal Supply Schedule (FSS) Pricing Disclosures. Significantly, in addition to the Price Reduction Clause (PRC) collection requirements, GSA, for the first time included the information collection requirements associated with the Commercial Sales Practices (CSP) submissions. GSA also specifically addressed and included burden hours and costs associated with training, compliance, audits, and reporting for the CSP and the PRC. The Coalition welcomes the greater level of awareness and transparency regarding the burdens and costs associated with these FSS pricing disclosure requirements. The Coalition looks forward to future opportunities to comment on the FSS pricing disclosures.
OMB Draft Policy on Software Licensing
On January 21st, the Coalition submitted its comments on the Office of Management and Budget’s (OMB’s) draft Category Management Policy 16-1: Improving the Acquisition and Management of Common Information Technology: Software Licensing. The draft memorandum seeks to establish a management framework for the acquisition of software across government while addressing contract duplication and identifying best practices. While the Coalition supports efforts to improve the acquisition of commercial software and reduce unnecessary contract duplication, there are concerns regarding the establishment of mandatory-use government-wide licenses and the creation of an Enterprise Software Category Management Team (ESCT) that will identify “best in class” solutions. The Coalition comments include a series of questions regarding the software management initiative. We look forward to hearing from OMB with feedback on our comments and questions on the draft memo.
Much can be learned from the DoD, GSA and OMB documents about the government’s approach to the management of data. As the sign on Under Secretary Frank Kendall’s door states “In God We Trust; All Others Must Bring Data.”
More on “bringing data” in next week’s blog!