This post is written by Women Impacting Public Policy (WIPP) and shared by permission.
In its June 23rd rule, the General Services Administration (GSA) finalized a new – and unnecessary – reporting requirement for federal contractors. The new policy will force contractors that sell to the government through GSA contracts, including Federal Supply Schedules (FSS) and Government-Wide Acquisition Contracts (GWACs), to report transaction or task order level data on goods and services. Effectively, companies will be filing with the government the details of what was purchased by the government.
The rule requires GSA contract holders to submit information including item descriptions, part numbers, quantities, and prices paid. When originally proposed, WIPP expressed concerns that the rule placed an unnecessary burden on contractors – requiring the reporting of data the government already had.
Unfortunately, the government has moved forward with this change. Beginning as early as August 2016, contractors will have 30 days to report this data and will need to continue to do so on a monthly basis. Recognizing the new requirement was effectively another price reporting system, GSA eliminated both the Commercial Sales Practices (CSP) disclosures and the Price Reductions Clause (PRC) in an effort to decrease the reporting burden. The change, however, simply replaces one reporting requirement for another.
GSA hopes to use the new reporting system to collect and analyze price data in order to improve the available data for federal purchases. The move is part of a broader multi-year effort to streamline acquisition. GSA plans on making some of the transaction level data available, which will allow contractors to better identify competitive pricing.
Testimony provided by WIPP’s government affairs team last June raised broad concerns that the proposed rule underestimated the time and complexity for compliance. It was noted that this was the fifth government system women-owned businesses would have to interact with. GSA’s response?
They increased the expected time and cost estimated for businesses to comply – but moved forward with the plan. GSA openly admitted in the proposed rule that they could build this system themselves requiring no additional information from contractors but they would not pursue that option at this time.
WIPP’s government affairs team also expressed concern that data on non-identical products and services could be misapplied by contracting officers. GSA responded that contracting officers are instructed to evaluate data within the context of an order, including unique attributes and socio-economic considerations.
The reporting requirement will be applied to any new GSA government-wide acquisition contract where transactional data is not already collected. It will be implemented over the next year in a series of pilots on specific schedules beginning this August.
The “pilot” will include eight separate Schedules and SINs:
Schedule 03FAC, Facilities Maintenance and Management: All SINs.
Schedule 51 V, Hardware Superstore: All SINs.
Schedule 58 I, Professional Audio/Video, Telemetry/Tracking, Recording/Reproducing and Signal Data Solutions: All SINs.
Schedule 72, Furnishing and Floor Coverings: All SINs.
Schedule 73, Food Service, Hospitality, Cleaning Equipment and Supplies, Chemicals and Services: All SINs.
Schedule 75, Office Products: All SINs.
Schedule 00CORP, The Professional Services Schedule: Professional Engineering Services (PES) SINs.
Schedule 70, General Purpose Information Technology Equipment, Software, and Services: SINs 132 8 (Purchase of New Equipment); 132 32, 132 33, and 132 34 (Software); and 132 54 and 132 55 (Commercial Satellite Communications (COMSATCOM)).
GSA has not announced the details of which schedules and SIN data pilots will begin first. The final rule can be found here.
The Voice for Women in Business in our Nation’s Capital, Women Impacting Public Policy, Inc. (WIPP) is a national nonpartisan public policy organization that advocates for and on behalf of women and minorities in business in the legislative processes of our nation, creating economic opportunities and building bridges and alliances to other small business organizations. Through WIPP, our collective voice makes a powerful impact on Capitol Hill and with the Administration.