The General Services Administration (GSA)’s Office of Inspector General (OIG) published a report on March 21, 2017, titled “Audit of Price Evaluations and Negotiations for the Professional Services Schedule Contracts.” According to the IG audit, GSA’s process to consolidate eight pre-existing schedules into the Professional Services Schedule (PSS) resulted in the award of new contracts without establishing price reasonableness. Contracting officers also used a combined “Pre and Price Negotiation Memorandum” template that does not conform to Federal Acquisition Regulations (FAR) and Federal Acquisition Service (FAS) policy. Finally, contract files lack sufficient documentation to determine fair and reasonable pricing. In February 2017, GSA’s FAS initiated price reevaluations for all 322 migrated contracts to ensure prices awarded were fair and reasonable.
GSA recently began posting drafts of upcoming solicitation refreshes for the Multiple Award Schedules (MAS) on its GSA Interact website for review and comment. One of the significant changes introduced in the November drafts is the Contract Continuity Initiative. Under this program, the Federal Supply Service (FSS) will offer a streamlined process for “successful” contract holders to use when submitting a new schedule contract proposal at the end of their 20-year GSA contract period. The Contract Continuity Initiative also provides the mechanism for contractors to maintain existing BPAs and orders under the old contract until it expires, while using the new contract for new work (‘continuous contracts’).
Why are these changes both necessary and important? The MAS program has reached the point where some contracts are approaching the end of the 20-year contract period. To date, such contractors have been required to submit a complete new offer, which creates an undue administrative burden on the contractor and GSA. By utilizing a streamlined set of instructions, GSA expects to expedite the process. According to GSA, “the following [solicitation] requirements were eliminated or reduced to the greatest extent possible:
There may be some changes ahead for the Department of Homeland Security’s (DHS) Continuous Diagnostics and Mitigation (CDM) contract resulting in favor of using the Alliant GWAC according to Federal Times. The products and services for Group F (containing many small and micro-agencies) will likely be bought off of GSA’s Alliant vehicle instead of the CDM Blanket Purchase Agreement (BPA). A BPA for the CDM contract was established which enabled agencies to buy security tools off a single vehicle. However, rather than getting individual security solutions, Group F will be treated as a shared services environment which means contracting officials will have to start out with high-level requirements and drill down to specifics further down the road. The BPA structure does not allow for this but the Alliant GWAC does. As Chris Hamm, director of GSA’s FEDSIM, described it, “You want to have the pay-by-the-drink style model … Right now it doesn’t exist [on the BPA], so I can’t buy it,” he said. However the Alliant GWAC allows for the flexibility of being able to buy services and parts and then decide on how something will get put together post-award. Important to note is that Hamm mentioned that using the Alliant GWAC for Group F is a special case and does not signify a “sea change away from the BPA”. A formal decision has not yet been made but DHS and FEDSIM officials are strongly leaning toward the Alliant GWAC. The solicitation is being written up with this route in mind and is expected to be released in the first quarter of fiscal 2016.
In June 2015, the General Services Administration (GSA) rolled out AdvantageSelect, a new service within its online ordering system, GSA Advantage!. An August 28 GSA Interact blog post summarizes: “AdvantageSelect draws concepts from category management, agile development, acquisition streamlining, and world class practices from Government and industry and is a game changing initiative for federal buyers. From this portal, a contracting officer or purchase card holder need only enter the quantity they require, and can proceed straight to check-out — so buying a commodity is finally as easy as click and pay. GSA has done the work for you by competing these items up front, applying category management principles and utilizing our latest procurement tools.”
Have questions about how GSA’s Professional Services Schedule (PSS) initiative affects your contracts? You aren’t alone. While GSA’s ultimate goal is to simplify the acquisition of professional services for its customer by creating a total solution for complex requirements via a single GSA Schedule, the process to implement the PSS has not been seamless. There have been numerous course corrections and revisions to the guidance given to contractors.
Join Aronson LLC experts Shawne Carroll and Joel Emmerich on July 16, 2015 for a complimentary webinar that will answer your questions and provide the latest news and guidance on the progress of this massive undertaking.