The Federal Acquisition Service has had one of its busiest six months in recent memory, with the General Services Administration's upcoming spring GSA schedule 2022 update to its federal marketplace strategy.
It's difficult to recall a period when FAS had to deal with so many moving parts. Since January, the changes and updates have come fast and furious, from the long-awaited transition to the Universal Entity Identification number (UEID) from the DUNS number to the now-much-maligned Polaris small business governmentwide acquisition contract (GWAC), to the unexpected challenges brought on by inflation, which affects nearly every aspect of the public and private sectors.
So, in case you missed some of GSA's critical work over the last few months, here's a quick rundown. This isn't an exhaustive list; rather, it emphasizes some of the most important memos, chances, and objects you may have overlooked.
GSA Schedule 2022 Federal Marketplace Strategy
Through the GSA schedule 2022 and GWACs that the FAS regulates, Sonny Hashmi, the organization's commissioner, continues to make the purchasing and selling experience easier.
GSA has announced that it would undertake a new buyer experience effort based on human-centered design to achieve this goal.
In an April 13 statement, GSA stated, "This breakthrough will eliminate pain points that federal agency purchasers, suppliers, and GSA acquisition experts have identified in feedback." "The improved buyer experience will provide buyers with acquisition tools and market research solutions, as well as paperwork, templates, and price resources to aid in acquisition planning."
GSA stated that its intentions with these news tools are standard, such as lowering responsibilities and streamlining the client agency's experience.
However, when you delve a little further, you'll find that FAS is attempting to solve several long-standing criticisms about its menu.
Inflation adjustments are still on the way.
Contractors requesting assistance to deal with the nation's 7.9% inflation were immediately responded to by the GSA.
On March 17, GSA's senior procurement officer, Jeff Koses, and FAS's Office of Policy and Compliance's associate commissioner, Mark Lee, temporarily modified restrictions around the Economic Price Adjustment (EPA) contract terms.
- Reduce the contracting director's approval for price hikes beyond the EPA clause ceiling to one level above the contracting officer;
- Reduce the time limits on EPA increases;
- Limits on the number of EPA increases a contractor can request should be relaxed; and
- GSA will not enforce the prohibition on adding the same item back at a higher price if a contractor has deleted an item from their Schedule contract.
"While EPA clauses are meant to protect GSA's interests, they are making it more difficult for federal agencies to get important goods, services, and solutions in today's market." Contractors are eliminating products from the Federal Supply Schedules contracts to avoid selling at a loss. In the memo, Koses and Lee write that "this damage new entrants and small businesses, the same enterprises that the President's procurement equity measures are designed to aid." "To guarantee that it can continue to offer a broad choice of products, services, and solutions, GSA must be flexible in how it implements these EPA contract terms." Despite the enhanced flexibility, contracting officers must still review price increases and decide whether to accept, negotiate, or remove items from the underlying contract.
The memo, according to the GSA, is still in effect until September 30.
While contractors praised GSA's fast response, the Coalition for Government Procurement has expressed concerns about how FAS contracting officers are putting the memo into practice.
The issue with any of these memos is getting it down to the contracting officers, and then ensuring that it is implemented consistently once they are aware of it.
The fact that FAS appears to be trying to reduce consistent changes to its contracting officers is troubling, especially considering that agencies have not adequately accounted for inflation and its impact on vendors.
For example, the Defense Department forecasted a 4% increase in inflation. On April 5, senior DoD officials told Congress that the military is currently facing the effects of a greater inflation rate than expected. The Department of Defense, on the other hand, has not disclosed any calculations on reduced purchasing power.
It'll be interesting to see how large of impact inflation becomes in the coming months, especially since agencies must spend six months' worth of cash in that time.
On Schedules, price is still a consideration.
One final decision made by the GSA based on GSA schedule 2022 that may have gone unnoticed by you occurred in February and was made public in March.
GSA opted not to use its authority under Section 876 of the 2019 Defense Authorization Act to exclude price as an evaluation factor when awarding a contract for its schedules program.
GSA decided that keeping pricing at the contract level, rather than the task order level, preserves the MAS program's present value after a series of listening sessions with industry and agency clients.
"Customer agencies raised grave reservations about transferring the pricing negotiating requirement from the contract to the order level. "The majority of agencies noted that this shift will considerably diminish the value of MAS contracts," GSA wrote in a blog post on March 23 based on GSA schedule 2022. "Stakeholders in the industry were split. It was acknowledged by some that it would save time. Others were concerned about internal market research and procurement acquisition lead time (PALT) at the order level."
GSA claimed in a white paper that an integrated project team held six listening sessions with agency and industry clients and came up with a list of "benefits" and "cons," as well as dangers.
The ability to minimize the workload of GSA's contracting officers, as well as industry support for the change, are both reasons why GSA should implement 876 authority under the scheduling program.
Meanwhile, there were a large number of reasons why the 876 authorities should not be implemented. GSA schedule2022, currently ensures competitive rates at the contract level, and agencies can ask for further savings at the order level based on volume buying, and contracting officers wouldn't have to undertake a formal, negotiated procurement at the order level, as required by FAR Part 15.
No comments:
Post a Comment