What's different about OASIS?

In September the General Services Administration declared its One Acquisition Solution for Integrated Services (OASIS) multiple-award contract program "open for business." OASIS and OASIS Small Business (OASIS SB), a small-business set-aside contract, are hybrid, governmentwide acquisition vehicles that offer an integrated approach to address both commercial and noncommercial requirements for professional services. In a recent interview with Federal Times Editor Steve Watkins, OASIS Program Executive Officer Jim Ghiloni explained why he expects the program to serve a critical role in federal procurement. Following are edited excerpts:

GSA has declared OASIS open for business. What interest are you seeing so far from the federal customer base?

There's a great deal of interest. We had opened OASIS Small Business a couple of months ago now [in June].

We've obviously already been engaged with customers about that contract. But now that we've got the full suite available, I think there's even more interest from customers.

We've been getting requests from a wide variety of agencies, civilian and DoD, for training, specifically the delegation and procurement authority training. But also for more high-level program training for acquisition executives and program officials and for senior procurement people within agencies.

We've already seen some task orders issued on OASIS Small Business from Veterans Affairsand the Air Force, and there may be others. We expect we'll see some more prior to the end of the fiscal year, and then going into the new fiscal year we'll see a swing in usage. There's a great deal of interest here right out of the gate. We are excited about that, and we expect it will just continue to grow.

You mentioned the training. OASIS is a hybrid contract. It's a unique vehicle in that sense. Is the training dimension of this more complex than what federal customers might be used to?

It depends on what they're used to. It's a different part of the Federal Acquisition Regulation that applies to OASIS. It's FAR Part 16, for those acquisition professionals in your audience. It's the same authority that's used for the GWACs and other large-scale IDIQs. So if they are familiar with contracts like Alliant or CIO-SP2, or SEWP, they'd be ordering out of FAR 16. Fair opportunity is the process. Some customers are familiar with that and some aren't.

In order to place orders against OASIS — and when I say OASIS, I'm generally referring to both OASIS and OASIS Small Business — a contracting officer needs to have a delegation of procurement authority, which is issued by our office. We do training as part of that process. We try to make this as painless as possible. It's about a 90-minute class that we provide on webinars. We do it on the phone. We do it in person where possible for customers, that's what our folks have been doing for the past few months. We'll continue to do it for the next few months. They're spending a lot of time on the road and going to major acquisition centers across the country and military bases, and other facilities to train contracting officers in how to use the vehicle appropriately, and answer any questions they might have and make sure they understand the process and GSA's role in that process. Then they go forth and prosper. Once they've got the delegation, they can place orders and use it like it's their own contract.

Can you discuss in a little more detail what early activity you are seeing?

I know that the Air Force was an early adopter. You reported on the Memorandum of Understanding [MOU] that we signed with Mr. Randall Culpepper [the deputy program executive officer for combat and mission support within the office of the assistant secretary of the Air Force for acquisition] earlier this year. The Air Force has made the OASIS contracts preferred vehicles for complex technical professional services that fall within the scope. There's going to be a large number of procurements coming out of the Air Force. They're ahead of the game essentially. They've really been planning for this for a long time.

A lot of their initial requirements are to support their various sustainment and procurement centers. There's some research and development that's coming out. I think that's an area that we're excited about at GSA. Traditionally, they've been done through the open market, in full and open competition or agency-specific contracts. Frankly, that's the reason the Air Force came to us; they acknowledged or understood that the cost internally to duplicate these contracts over and over again was costing them time and money and resources. By building on the platform of the OASIS program, they're able to eliminate that duplication to free up those resources, to focus on mission work, to focus on oversight and superior performance. We think that other agencies will also see the value of it as they become familiar with the program.

We asked one of our partners, Govini, a market research firm, to look at the OASIS scope of business in past years. The NAICS code for R&D engineering and science is one that has seen a 10-plus percent CAGR growth in recent years.

This is a new area, really, for GSA. What kind of business do you expect to see in this area?

Well, OASIS allows for a broad scope of professional services. One of the core disciplines is scientific support as well as engineering. While GSA has been able to support those tasks in smaller doses, I think there's a new customer base out there that has, again, traditionally done these things open market or done their own procurements. This will enable them to get to those service providers that we see on OASIS.

If you look at the contractors that are available in those pools on OASIS that cover R&D tasks, you will see a lot of the industry leaders, the companies that one would expect, the top 10; but you will also see a lot of very innovative midsized and small companies that are doing really great work for particular customers like NASA or Air Force or the Army or the Navy in that community.

And so what they get with using OASIS is a streamlined way to get those solutions in place in a timely manner. They don't have to spend a lot of time doing acquisition. They can get right to work doing the research and staying innovative and getting cutting-edge technologies and services from our providers.

Is GSA viewing OASIS as a way to capture a larger share of the DoD procurement market?

Absolutely! I think OASIS really is helping us open new doors at DoD.

Mr. Culpepper at the Air Force has been kind enough to bring me along to meetings at the Pentagon with senior DoD officials to talk about OASIS. And they've been very positive, I think, to our responsiveness to their concerns for accommodating a wide variety of contract types and for giving them a selection of excellent companies, but also to be able to do a streamlined acquisition, [which is] something they really need to get their mission done with their limited resources.

I think GSA is trying to leverage some of those relationships and some of the lessons learned on OASIS into and across our entire program. I'm sure you're aware of our category initiatives, setting up category management and building hallways for customers to get that one-stop shop. They can get information about different fields in our professional services hallway.

OASIS has been billed as being a streamlined solution for both commercial and noncommercial requirements for professional services. Can you discuss how the contract will save time and money for federal customers?

The benefit of using an IDIQ like OASIS for a customer is if the customer has a requirement and they need to acquire the services to meet that requirement — if they were to essentially start from scratch and do their own formal procurement in accordance with the full barrage of the Federal Acquisition Regulation that could take them a year or more. There are a wide variety, if you think of the acquisition processes, of steps on a list. On OASIS, we've done 80 percent of those.

For example, we've looked at the financial responsibility of these companies, we've evaluated their capabilities, their past performance, we've ascertained that they're capable of providing service at a high level, that they have a successful history of providing excellent performance at a high level, they're financially stable, they're not going to go bankrupt in a month, et cetera. We've done a lot of these steps, the sifting through the hundreds and hundreds of offers that we got to get to that cadre of outstanding industry partners.

Now, an agency, rather than doing all of those things, which again can take months and months, they focus on their specific requirement. They place that task order out. They know that any of the 40 or so companies that are competing for that work, are going to be able to support it. They're going to get a high quality proposal from highly qualified companies. They can focus their evaluation on technical factors that are true discriminators rather than having to, again, jump through all of those acquisition hoops that we have already done on their behalf. Instead of taking six to eight months or two to three years to do something like this, they can take six to eight weeks to get something out the door.

They have their requirement. They compete it for say four to six weeks. They take four to six weeks to evaluate it and they place an award. They focus that on technical excellence and value — the best value they can get, competitive pricing through a competitive process. But also no restrictions on teaming or solutions that are being provided — industry is able to provide the right solution for the requirement without any hindrance based on the broad scope that we've defined for OASIS.

In your conversations with various agencies, potential customers, what are you hearing from them in terms of what is trending in the way of this convergence between professional services and IT services?

Yeah, it's a fine line. Frankly, it's one of the reasons we work very closely with our friends in the Alliant program who are seeing obviously the complex IT requirements. We look at scope statements. We look at statements of work jointly, we share notes with them. Because there are so many requirements that fall in a gray area that have both, that have highly technical [aspects] and really look kind of like an IT requirement. But maybe it's for a national security system — therefore, it's not IT, by formal definition.

But you can do IT on an OASIS task order as long as it's ancillary to a broader solution. If IT is itself the requirement, then it needs to go onto an IT contract. That's why, again, we talked to those folks over in our ITS [Information Technology Services] organization to make sure that we are all in the same page as far as how we are approaching customers, and helping them understand their requirements. Generally what it boils down to is, what is the mission of the customer? What are they really trying to accomplish? They may say that they need a system or some people to do something, but their mission generally isn't to have a system or to have people — it's to support the war fighter or to cure diseases or prevent Ebola outbreaks or explore space. We can talk about what your requirements are and what you need to do that. And that's going to take us to, 'Is this an IT requirement? Is this a professional services requirement? If it is not IT, is it something else entirely? What's the right vehicle for you to get there?'

Other GWACs — whether it's SEWP or CIO-SP, or what have you — also offer complex IT solutions often within the context of other professional services. How does OASIS fit into that? In other words, do you expect that some business currently on those other GWACs will come to OASIS because it streamlines things even further?

No. I think if you look at the companies that are on OASIS, you'll see a lot of them have Alliant contracts, a lot of them are on SEWP and CIO-SP2 and SeaPort, and all these other vehicles.

IT is a pretty segregated set of requirements. You can go to the Clinger-Cohen Act that defines what IT is. When we did Alliant, we actually just took right out of Clinger-Cohen: This is what IT is, and if it's this, then it's in scope. That's what the scope of Alliant is.

What we've said on OASIS is it's everything else that's not IT professional services. If it's professionals doing labor — if it's that predominately — then it's OASIS. You can have facility maintenance, or minor construction, or IT as ancillary. Ancillary is a big word for us in our world. "Integral and necessary to," but ancillary to the actual requirement.

The challenge — and I think you've latched onto this — is it really depends on how you define that requirement. That you could take essentially a piece of work or an agency's requirements — depending on how you wrote that or how you really defined that — it could take you one way or the other because it really does sit in that gray area. It comes back to what is really the focus. That's why, when I have these conversations with the customers, I again drill down to: OK, what's your mission? NASA is to explore space, and weather, and things like that. But at Goddard, you are doing earth science; and at Wallops Island, you are doing research into weather patterns. OK, you are doing weather patterns. What are you trying to do? We are trying to study how weather patterns affect this and that. Okay, that is not an IT requirement. That is a scientific research requirement. There are IT components to that. You may need some sort of system to track it. But that is what you are trying to accomplish.

How should a federal customer look at the small business dimension of this? How should they decide whether to look first at the small business contract versus the non-small business? Is it based on the dollar figure or is it something?

It's a pretty common question. It's actually part of the training that we go over. We spend some time on this. There is pretty rock solid case law on this. There was some case law with different Court of Federal Claims rulings that really solidified our approach and validated it from our point of view. What that essentially says is the decision of whether or not to set something aside for small business is made pretty early in the process of acquisition, long before you pick the contract.

You're not choosing between OASIS and OASIS Small Business. You've got a requirement. You as a contracting officer — as part of your acquisition planning — need to do whatever market research is necessary to determine whether or not small business can perform. Now, we've got something called the rule of two which states that there are two qualified small businesses that can do something, you should set it aside for small business. Beyond that, though, there's really not a whole lot of specific regulation on how to make that determination. It's left to the judgment of the contracting officer. We deal with lots of agencies at GSA and I've seen this done dozens of ways. Because there are a number of factors that enter into it: Geographical complexity, just sheer dollar volume; the number of people that it's going to employ, the complexity of the work, the resources the company needs to draw on to support the work. There is just a number of security clearances that enter into it sometimes. There is a variety of things that can dictate whether something can be performed by small business or not. So that market research will take place. Now what we do is we try to help customers with that.

What our job at GSA is one to give them a solution no matter which end of the flow chart they end up on. But then, more importantly is to help them make those determinations appropriately and to make sure that customers are aware of the capabilities of small businesses. Because we see in a lot of cases, small businesses are capable of an awful lot and really can do a lot of great things.

We saw that directly in our evaluation process. We asked these companies to show us examples of what they have done. Frankly, some of the things these small businesses are doing are incredible, really amazing projects. We try to be a champion for them and to get that word out. But having said that, it's hard for a company that is 50 employees, $10 million a year to support a requirement for $800 million dollars, a thousand people all across the globe. That might be a tough fit.

What feedback are you getting from your interactions with the federal agencies, specifically about the small business dimension of OASIS?

We signed the MOU with the Air Force and their intent, frankly, was for almost all of their money to flow into small business. It's probably close to a billion dollars a year just from that one customer to the small business community, maybe more.

We think there's going to be extensive opportunities for small businesses on OASIS SB. And that hopefully they'll very rapidly outgrow small. So we fully expect that at the five-year point we'll be able to transition those companies from the small-business contract to the full and open one through an on-ramp process.

What mechanisms have you built into both the small business and the regular OASIS vehicles to generate robust competition?

We talk about healthy competition. Competition drives innovation. Competition drives efficient pricing. It really is invaluable for us. At the same time, we don't want to see what we call unhealthy competition, where you get proposals and one is excellent, two above average, and 15 that are average or below. Yet you've got to spend as much time on every single one and document that.

We are talking about healthy competition. For us, that means really three to five bids per task. We think that is a good number, it gets good competition, but is not going to overwhelm the resources to the customer agency and put them behind schedule. Based on our experience managing different GWACs and IDIQs, we felt out of the gate that about 40 companies was the right number to get on average three to five bids per task. But we are going to monitor that very closely.