As you know, putting “commercial” back into commercial item contracting is one of the Coalition members’ top priorities. Over the last decade the procurement community has seen a significant growth in the imposition of government unique requirements on the procurement of commercial services and products.  This retreat from commercial item contracting increases costs, reduces competition, limits innovation and costs jobs.  Given the budgetary challenges we are facing, the federal government cannot afford to continue impose unique terms, clauses and regulations on commercial item contracts that increase costs while adding no value.  It is time for a retrospective review of commercial item contracting, including the GSA Multiple Award Schedules (MAS) program, to identify and remove costly, unnecessary government unique terms, conditions, and requirements.

Conducting a retrospective regulatory review that focuses on putting “commercial” back into commercial item contracting is good for the taxpayer, the federal government, and the private sector.  It is also consistent with President Obama’s January 18, 2011 Executive Order 13563—“Improving Regulation and Regulatory Review” and May 10, 2012 Executive Order 13610—“Identifying and Reducing Regulatory Burdens.”  These Executive Orders seek to “modernize our regulatory system and to reduce unjustified regulatory burdens and costs.”  To that end, reducing unnecessary regulatory burdens and costs on commercial contractors will increase the efficiency and effectiveness of the federal procurement system.  As a result agencies will be better equipped to meet mission requirements in a more cost effective manner.

The best place to focus such retrospective review is GSA and the VA MAS program.  The MAS program is the foundation for government-wide commercial item contracting.  The $50 billion MAS program is the largest government-wide commercial item contracting program.  (Orders under the GSA MAS program account for approximately $40 billion annually while the Department of Veterans Affairs MAS program accounts for another $10 billion in orders each year.) As such, the taxpayer has a wonderful opportunity to increase MAS efficiency and save money by reinvigorating commercial item contracting.  To that end, in the October 26th Friday Flash the Coalition requested your input as to those terms, conditions and regulatory requirements that are inconsistent with commercial practices; increase costs and/or reduce program efficiency.  Your input will form the basis for an ongoing “Myth-Busters” conversation with GSA, VA and its stakeholders on the imperative of “putting commercial back into commercial item contracting.”

Consistent with the Myth-buster’s initiative, FAS has requested this input as part of the continued dialogue on GSA programs that took place at our Fall Conference.  Please remember that suggestions are welcome from the entire procurement community, including government and the private sector.  Thank you for the comments we have already received to date!  For those of you who have not yet responded, please provide your comments/input to Roy Dicharry at by November 30th.