GSA Pricing Tools, Untooling

A GSA internal watchdog has found the two comparative labor pricing tools contain flawed data and recommends GSA stop using the pricing tools. GSA however, plans to keep the current pricing tools in place for now. (FCS, January 2, 2020)

This report shows the use of discrepant data in flawed equations, thus arriving at unreliable pricing data. GSA’s Inspector General (IG) said, “the data and calculations are so flawed, they’re dulling the federal government’s buying power edge, as well as possibly resulting in the overpayment on contracts.” (ibid)

Julie Dunne, FAS Acting Commissioner, agrees with the IG that the two tools, Contract-Awarded Labor Category tool (CALC)  and Contract Operations Division Contractors Database (CODCD) used for labor pricing, are not the optimal. She also agrees about a need for pricing comparison capabilities; however, she refrains from wanting to scrap these tools in lieu of something else that might bring even greater inaccuracies. 

Dunne went on to say that without the current tools, labor pricing would be determined by individual searches via the internet resulting in more inaccuracies. She acknowledged that decisions on comparison pricing for labor have always been the judgment of FAS contracting officers. “Disallowing access to aggregated information about previously-awarded MAS contracts does not further our goal of improving pricing. Quality price analyses are the result of training, expertise and appropriate controls. FAS believes our continued focus in these areas will improve how comparative data is used in our MAS award documentation.” (ibid)

Have questions concerning your current labor pricing? Give us a call.

Federal Supply Class Review

What happens when the Defense Logistics Agency (DLA) and the General Services Administrations (GSA) get together to increase efficiencies and effectiveness of the national supply chain? You get the first Federal Supply Class (FSC) review in almost 50 years. (Defense Logistics Agency, October 9, 2019)

So why now, you ask? According to Alan Thomas, commissioner of GSA’s Federal Acquisition Service, it is to “optimize the movement of supplies to our nation’s troops and reduce duplication in the federal supply chain.”

FSC’s review involves all 600 FSCs, or about seven million items used by federal and military consumers and categorizes them by similarity. This review will reduce redundancies and improve purchasing efficiencies as well as customer readiness and responsiveness. Checks and balances will keep both organizations compliant with principles of their original agreement. (ibid)

The 1971 Supply Management Relationship Agreement between DLA and GSA gave DLA authority over supplies within assigned FSCs used by the military regardless of their use by civil agencies. GSA manages items used by federal agencies that are commercially available. Today GSA and DLA  maintain contracts with vendors delivering directly to customers. DLA forecasts demand and then supply chain representatives, vendors and DLA Distribution ensure on-time delivery worldwide.

DLA and GSA are working side by side to put together an automated tool that categorizes FSCs for analysis. The tool will produce summary-level data on all items to ultimately determine if a change in acquisition strategy might lead to improved efficiencies and effectiveness for the government, taxpayers, and customers. Both DLA and GSA must be in agreement to transfer logistics management of any items.

“Regardless of item transfer decisions, the process and tools we’ve developed in conducting this review provide an archive of information that supports FSC management determinations beyond the simple criteria identified in the 1971 agreement,” Jay Schaeufele, GSA account manager for DLA Logistics Operation’s Whole of Government Division, said. “This information is important as we navigate government and acquisition reform initiatives and evaluate potential economic efficiencies without losing vision of DLA’a first priority to warfighter readiness. (ibid)

Jeff Thurston, director of GSA’s Office of Supply Chain Management, said: “GSA’s new business model challenges us to identify new ways to serve environments where stocking product was previously the go-to solution.” (ibid)

The Commercial Platforms Program will update how commercial products are bought by federal agencies via partnerships with commercial e-platform providers. Government agencies will access commercial platforms as part of a whole-of-government approach. This approach will give agencies visibility into online spending, thus reducing supply-chain risk while providing more time for focusing on mission-oriented acquisition.

According to Laura Stanton, deputy assistant commissioner for Category Management in GSA’s Office of Information Technology Category, “this three-year proof of concept will offer federal buyers easy access to e-marketplace providers and commercial products. Additionally, agencies will have better visibility and insight on purchasing patterns to bring one-off spending under management. The Commercial Platform’s proof of concept offers a way for agencies to access commercial platforms as part of a whole-of-government approach, strengthening GSA’s commitment to maximize the government’s buying power through economies of scale.” (ibid)

GSA and DLA are consolidating purchasing, tracking, and spending analysis while taking advantage of government-wide and best-in-class acquisition vehicles. In addition, they are working together to communicate supply chain issues such as cybersecurity, fraud, and counterfeit parts while working with the military to determine optimal shipping routing.

Will this translate into possible changes to your current contract or bid? We’re available to discuss.

GSA’s New Rules!

GSA has issued a final rule amending the following parts of  the GSA Acquisition Regulation (GSAR):

  • Part 515, Contracting by Negotiation,
  • Part 538 Federal Supply Schedule Contracting
  • GSAR Part 552, Solicitation Provisions and Contract Clauses (GSA Interact, June 3, 2019)

The above changes were enacted to clarify, update, streamline and incorporate existing Federal Supply Schedule contract administration policies and procedures. The final rule became effective on May 23, 2019. (ibid)

Changes include the following:

  • deletion of 85 obsolete/duplicative clauses and provisions (see GSA Order ADP 29800.12B Change 100)
  • incorporation of 30 “new” clauses and provisions into GSAR.
  • reincorporation of four GSA Schedules program clauses and provisions (previously removed from GSAR in a rewrite) into GSAR.
  • updating 10 existing GSA Schedules program clauses and provisions to reflect current references and practices. (ibid)

The above changes will be part of GSA’s new Consolidated Schedule solicitation. More information to follow in the coming months.

If you have questions about the GSAR rule amendments will affect your contracts, give us a call at 301-913-5000.

 

Price Inconsistencies on Schedule 70? Nah…

GSA’s IG audit of GSA schedules in 2016 found large price discrepancies between identical items. For instance, the cost of one of Sharp’s 70-inch LED Smart TVs showed prices ranging from $1,597 to $3,000. The audit also turned up prices much lower on commercial products. In addition, from August 2014 to July 2015, most IT schedule purchases were for top-selling items priced higher than the lowest IT schedule price, completely defeating the purpose of the Schedules program. (Nextgov, May 21, 2019)

Recommendations to correct the disparities include:

  • Verify prices for identical IT schedule items by price analysis
  • Improve price protection for IT schedule reseller contracts by setting controls
  • Ensure contracting officers receive accurate and complete information around manufacturers’ commercial sales practices (ibid)

Per the review by the IG, the Federal Acquisition Service has taken “appropriate corrective actions” to address these price inconsistencies.

Questions about IT Schedule or other GSA Schedule pricing? Give us a call at 301-913-5000.

The Future is Cloud-y

In February, GSA released a draft request for proposal (RFP) to consolidate and upgrade all of the Defense Department’s back office functions into the commercial cloud. GSA’s Federal Acquisition Service is now in the early stages of doing the same for civilian agencies with Civilian Enterprise Office Solutions (CEOS). (Federal News Network, May 7, 2019)

To help ensure supply chain security, DHS took the lead on early efforts. GSA has taken over efforts to reduce the attack surface of the network. With managed service, security is already embedded in the solution, making it more secure than the currently situation. (ibid)

Alan Thomas, GSA FAS commissioner and a board member managing the Technology Modernization Fund (TMF), has recommendations/lessons learned for agencies applying for Fund loans to modernize their IT:

  • Agencies submitting proposals this year need to build incremental benchmarks into their proposal, or their funding will likely be pulled.
  • Quarterly reviews will be conducted on agencies receiving funding.
  • Agencies should make sure their proposals focus on value creation and cost savings as the agencies must pay back funding provided by TMF.
  • Agencies should coordinate internally on proposals prior to submission; otherwise, they run the risk of being turned down for funding. (ibid)

FAS is also in need of IT modernization. The FAS internal systems, FSS 19, is nearly 40 years old. It uses older programming languages (COBOL, PowerBuilder) that solved specific problems instead of approaching an integrated solution. FAS is in need of a new, updated IT solution to bring the agency out of the 1970s. (ibid)

Are you a software provider or integrator looking to bring civilian agencies into the 21st century? Let’s talk! 301-913-5000.