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Contracting program must keep offering open seasons

Oct. 28, 2012 - 02:32PM   |  
By ROGER WALDRON   |   Comments

The Multiple Award Schedule program is the most successful commercial item contracting vehicle in the federal government, accounting for $50 billion in annual purchases through General Services Administration and Veterans Affairs Department federal supply schedules.

One reason for the program’s success is continuous open seasons, which provide small, medium and large commercial firms an opportunity to submit an offer for a schedule contract every business day of the year.

But now this key competitive attribute of program success is in jeopardy.

On July 23, GSA’s Federal Acquisition Service published a Federal Register notice announcing implementation of a Demand Based Model for the MAS program. Central to the DBM is elimination of continuous open seasons for certain schedules.

The notice states in part, “GSA is proposing this operational change to enhance performance of and modernize the MAS program in three key program areas: small business viability, operational efficiency and cost control.”

FAS cites the costs associated with the number of low-sales and no-sales MAS contracts in making the case for eliminating continuous open seasons.

Continuous open seasons reflect a faith in the commercial market providing access to the latest commercial services, products and solutions for GSA and its customer agencies. Keeping the schedules open to new offers enhances competition and innovation while ensuring that the program’s procedures meet the statutory mandate that contracts and orders are open to all sources.

At a time when government is seeking greater opportunities for small business concerns through its Small Business Jobs Act of 2010 initiatives, eliminating continuous open seasons will limit small business opportunities. How many times has a small business entrant to the federal market been asked by a contracting officer, “Do you have a GSA schedule?”

Coalition for Government Procurement members, most of whom are MAS contractors, should favor closing schedules, as it would reduce the competitive field.

However, they do not. They understand that continuous open seasons are vital to providing customers with access to the latest commercial innovations and solutions. Rather than eliminating continuous open seasons, here are four reforms to increase opportunities for customer agencies and MAS contractors:

Consolidate program management in a single office within FAS. The MAS program is managed across three, perhaps four, business units within FAS. As a result, policies, procedures and contracting strategies often differ across the program. This increases complexity, uncertainty and costs for customer agencies, GSA and contractors.

A centralized management team would enhance consistency and reduce duplication of functions across FAS business lines while maximizing GSA’s acquisition resources.

Adopt Federal Acquisition Regulation-based contract structures for the acquisition of commercial solutions. Since at least 2008, FAR has included standard commercial item contracting clauses that include accountable, flexible mechanisms for the acquisition of materials; other direct costs and indirect costs as part of a commercial item contract. GSA has yet to use these standard FAR terms in its MAS contracts.

Adopting these terms would increase task order competition and contract efficiency, translating into cost savings for customer agencies, GSA and contractors. This is an opportunity to better meet customer needs, reducing contract duplication.

Empower the “consolidated” contracts. Under the consolidated contracts, a MAS contractor can “consolidate” or combine several MAS contracts into a single, comprehensive contract covering all its services and/or products, reducing costs, increasing efficiency and enhancing competition. The current consolidated contracting process is unduly burdensome and time consuming.

Put “commercial” back into commercial item contracting by removing unique requirements and clauses inconsistent with commercial practice from the MAS program. These requirements add costs ultimately passed on to the taxpayer.

Pursuing these four reforms would help GSA achieve its goals of better using acquisition resources, lowering costs and modernizing the schedules program, while creating greater opportunities for customer agencies and MAS contractors. These reforms are also consistent with acting Administrator Dan Tangherlini’s vision for GSA as an innovation center.

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Roger Waldron is president of The Coalition for Government Procurement, a trade association of commercial firms involved in governmentwide contracting, including the Multiple-Award Schedule program.

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