Category: Rules and Regulations

Innovation and Commercial Items: The Department of Defense Can’t Have It Both Ways.

  In policy pronouncements and public statements over the last year, the Department of Defense (DoD) emphasized, as a strategic imperative, gaining access to, and leveraging, innovative commercial technologies. For

Federal Acquisition Service’s Competitive Pricing Initiative

The Federal Acquisition Service’s  (FAS’s) Competitive Pricing Initiative (CPI) is intended to address price variability for identical items under competing Multiple Award Schedule (MAS) contracts.  An unintended, positive consequence of

The New Fair Pay Rules: Increasing procurement complexity, burdens and costs for government and industry

On May 28th, the Department of Labor (DOL) published the proposed guidance implementing Executive Order 13673, Fair Pay and Safe Workplaces (the E O).  On the same day, the FAR

Roger Waldron’s Letter to Administrator Roth and Administrator Rung

For this week’s comment, I wanted to share with you all a letter the Coalition sent this week to OMB and GSA concerning commercial item contracting in the wake of a

More on GSA’s Push for “Data Transactional Reporting”

This blog addresses GSA’s proposed rule seeking to implement “Data Transactional Reporting” for the GSA Schedules program, GSA IT GWACs, and other GSA contract vehicles.  In my March 6th blog,

Transactional Data Reporting: Does the American taxpayer really want wage and price controls?

  On March 4, 2015, the General Services Administration (GSA) issued a proposed rule, GSAR Case 2013-G504, Transactional Data Reporting.  The proposed rule would establish a new requirement for GSA

Data, Data, Data

The current procurement passion for collecting data, in particular prices paid data, raises many policy questions.  Coalition members have, on a number of occasions, indicated that data is not a

Revisited: Unintended Consequences of the FAR 8.4 Rewrite

This week’s topic is the “Unintended Consequences of the FAR 8.4 Rewrite.”  Simply put, the rewrite removed a strategic acquisition tool, single award Blanket Purchase Agreements (BPAs), from customer agency procurement tool

GSA Issues Notice to MAS Contractors on “Improving Product Number Data Quality on GSA Schedules”

  Yesterday GSA issued a notice to its Multiple Award Schedule (MAS) contractors entitled “Improving Product Number Data Quality on GSA Schedules.” The notice states the GSA is seeking “to

Thoughts on “Modernizing GSA’s Schedules Program…”

On June 12th Tom Sharpe, Commissioner of the Federal Acquisition Service (FAS), posted a new blog entitled “Modernizing GSA’s Schedules Program for Today’s Marketplace.” As you may recall, earlier this year GSA published