Uncle Sam Wants You … To Comment on Acquisition Regulations

Per the Trump administration’s mandate, GSA continues to streamline federal regulations. They have subsequently requested industry comment on policies that may be due for repeal, modification, or replacement. GSA especially needs input on less recent items, such as evergreen contracting. The office also encourages information on newsworthy topics such as the Transactional Data Reporting rule.

Of particular interest are regulations that inhibit job creation, seem outdated, have more drawbacks than benefits, create serious inconsistencies, derive  from non-transparent data, or rely on executive orders that have since been rescinded.

Send in your comments to take advantage of this opportunity to comment  on GSA’s policies and practices. Read more at https://www.gpo.gov/fdsys/pkg/FR-2017-05-30/pdf/2017-11052.pdf

 

Summer Slow Down

As we pass Memorial Day, the unofficial start to summer, it’s helpful to remember that your GSA Contracting Officer (CO) will most likely have a vacation coming up, just like you.

If you know that an important RFP release is imminent, which will require modifications to your Schedule, we strongly suggest you begin working on the mod requirements now. Time-sensitive changes can bring showers of stress to your lazy summer days, especially if you find out that your CO has just left for a three-week vacation/training on the day you submit. To ensure smooth sailing, give your CO a heads-up about the upcoming mods in advance; ask the CO when s/he expects to be out and how you can avoid lengthy delays of a modification.

Being pro-active now can save you the pain of a lightning strike in mid-July! If you need help with a modification or have further questions, contact your EZGSA proposal specialist at 301-913-5000 or email us today.

Welcome to the Jun(GSA)le

GSA opening up to businesses and industry partners

Jack St. John, Chief of Staff at GSA, has released a statement promising GSA will be more business friendly by improving industry partnerships, streamlining acquisitions, and easing the onus  of regulations. He announced that GSA will make Transactional Data Reporting optional and asked for public comment in reexamining the policy.

Also of interest to many of our clients, Schedule 75 for Office Supplies and Services will reopen, making a significant statement about increased access to dynamic pricing and innovation from the competitive marketplace. St. John further outlined GSA’s goals for uniting and simplifying the Professional Services Schedule (PSS) to increase the efficiency of the contract for agencies and industry partners. The suggested PSS solicitation is available to read and open for comment until May 26.

You can read more about it here or contact EZGSA at 301-913-5000 or mbotello@ezgsa.com

EIS Schedules (tele)Coming to America

GSA Asks for Industry Help Transitioning to EIS Contracts

GSA is moving small agencies and Native American tribes that hold telecommunications Networx and WITS 3 contracts to Enterprise Infrastructure Solutions(EIS) contracts. Officials expect a May 2020 completion date for the transition.

GSA asked industry for input on how to transition these 36 entities to the new plans.

If groups do not have the resources to transition, they can ask GSA to do most of the heavy lifting. However, groups that use this service must reimburse GSA through contract fees.

For more information, read the RFI.

Effectiveness of TDR is TBD

GSA Responds to Criticisms of TDR

The new pilot program for Transactional Data Reporting has met widespread criticism, leading many to question its supposed benefits.

GSA wrote the Transactional Data Reporting (TDR) requirement as an alternative to the Price Reduction Clause (PRC) and Commercial Services Practices (CSP) provision, in response to contractor complaints. The CSP provision requires government contractors to inform GSA of any discounts they offer to commercial partners. Meanwhile, the PRC requires contractors to offer government clients discounts equal to those given to commercial customers, as determined by the contract itself.

Because vendors tend to loathe these clauses, the TDR requirement generated widespread enthusiasm before its June launch. However, since then, it has met with criticism from the contractor side and has included anecdotal evidence of contracting officers still requesting CSP, or CSP-esque information from contractors enrolled in the TDR pilot.

Kevin Youell Page, the deputy commissioner of the Federal Acquisitions Service has publicly stated that “We haven’t really heard from anyone that this has specifically happened.” Most of the criticism appears based more on worries that COs could still require these, as well as general apprehension. Nonetheless, Youell Page is trying to answer feedback and reform the program. FAS has set up an email address exclusively for questions, comments, and concerns about the program; worked closely with the inspector general’s office to alleviate confusion; and continues a cross-country campaign to train and educate contractors and stakeholders.

This is a dramatic shift, made more  so by the risks associated with the new administration. GSA has only committed to a three-year pilot, and as yet the Trump administration has not moved to support TDR. This creates concerns about the liability of participating contractors for PRC and CSP data after the pilot ends.