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Tim Atkin

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SRA has been a GSA partner since the services-focused GSA Multiple Award Schedules (MAS) were first put into place and we’ve seen the federal government market realize the true value that these contracts bring to meeting the mission needs of multiple agencies. We’ve also seen that, over time, government and industry have become increasingly adept at leveraging these contract vehicles. This next step in the MAS consolidation is a further opportunity to evolve the way we do business and help us all be more efficient and agile. A great example of this is Federal Acquisition Service Commissioner Thomas Sharpe’s Category Management initiative. This is an encouraging opportunity to bring better education, understanding, and best practices to ordering agencies across the federal government. This should help bring more clarity when matching scopes of work to specific schedules, enabling agencies to focus on solving their most important challenges. Taking this one step further, establishing interactive spaces within the so-called “hallways” for customers and contractors to collaborate in virtual market research would be welcome. GSA has seen success with

Barbara Kinosky

this type of industry interaction on the recent OASIS Interact site, and is also using it for the upcoming Alliant 2 procurement. Initiatives like these drive efficiency and help to ensure that taxpayer dollars are being used in the most efficient manner.

An Industry Perspective on GSA Professional Services Schedule Contracting Standardization of Labor Categories

From the inception of the MOBIS contracts nearly 20 years ago, GSA has applied a product acquisition model to professional services acquisition. MOBIS flourished and spawned several other professional services schedules that have been embraced by the federal market. The multiple layers of competition (at the schedule and task order levels) have driven competitive pricing, ensuring federal agencies get the best deals. We’ve seen a trend toward labor category standardization over the last five years. This is challenging in the professional services market, which is an amalgam of diverse functional capabilities. We should be careful and cautious about the possible “commod-

itization” of professional services. It is best to allow industry to deliver the best value to customers, as opposed to being evaluated based on standard labor categories and lowest price technically acceptable (LPTA) criteria. Schedule holders customize each proposal based on the customer’s specific requirements, bringing together a tailored mix of talent and technology to deliver winning solutions within limited budgets. Before mandating standardized labor categories on the GSA Schedules, we recommend consideration for the flexibility in labor category descriptions that contractors need to offer so that we can represent the unique capabilities of the workforce that is the differentiator in our ability to successfully execute on the opportunities we choose to pursue. Ordering agencies should have the flexibility to receive offers and make awards to schedule holders who best meet their agency specific requirements. Keep the flexibility with the contractors, the choice with the ordering agencies, and let the market drive the price. An acquisition system with speed, agility, transparency and competitiveness that provides the services that meet the customers’ mission needs is the desired outcome. 3

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ing that 84 percent of the pre-award audits conducted on schedule contracts in fiscal year 2012 found commercial sales practices (CSP) disclosures that were not current, accurate, or complete. The IG also found that if the CSPs had included accurate and complete information, the government could have potentially realized cost savings of up to $188.5 million. What my colleague Jennifer Aubel of Fed Nexus Law noted as being of particular interest is the fact that GSA is not doing anything to address the fact that the CSP is seemingly designed to encourage incomplete or improper disclosures. After all, it’s not

like the OIG does audits on random GSA Schedule contractors. They focus on high-volume contract holders in order to maximize the opportunity for recoveries. If these overachievers can’t fill out a CSP correctly, what chance do mere mortals have of making compliant disclosures? • Revisit how GSA is rolling out its plan to reduce prices In recent solicitation refreshes, GSA quietly added an interesting caveat to its pricing language. This new language states: “Fair and Reasonable Pricing: To determine fair and reasonable pric-

ing, the GSA Contracting Officer may consider many factors, including pricing on competitor contracts, historical pricing, and currently available pricing in other venues. Offers which provide Most Favored Customer pricing, but which are not highly competitive, will not be found fair and reasonable and will not be accepted.” GSA is now reserving the right to assess price reasonableness, not only in relation to a vendor’s own commercial sales practices, but also in relation to the prices currently offered by other vendors for the same or similar items. This new policy means that if a vendor’s continued next page

14 / Service Contractor / December 2014

Professional Services Council

Profile for Professional Services Council

PSC's Service Contractor Magazine - December 2014  

PSC's Service Contractor Magazine - December 2014