Failure to Implement Other Direct Costs in MAS Contracts

Issue: Failure to incorporate/utilize FAR 52.212-4, Alternate I in Multiple Award Schedule contracts. This gap in the MAS program limits competition, increases costs, fosters contract duplication and reduces efficiency.

FAR 52.121-4, Alternate I provides the contract mechanism/procedures for including Materials, Other Direct Costs and Indirect Costs in commercial item contracts. The failure to utilize this FAR-based clause in MAS contracts limits flexibility, efficiency and competition under the MAS program. As a result the MAS program is encouraging/fostering contract duplication by customer agencies who cannot acquire complete commercial solutions under the MAS program.

Recommendation: FAR 52.212-4, Alternate I is in most MAS contracts. Agencies should be authorized to utilize the clause at the task order level to compete and acquire total commercial solutions that include materials, ODCs and indirect costs.

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1. Reporting and Compliance

Campaign 1: Reporting and compliance requirements - Currently, the Federal Government requires businesses to fill out a lot of complicated paperwork to do business with us. We know we can do better. We want to know what you are seeing – where can we reengineer paperwork and systems, eliminate duplicative reporting, reduce the frequency of reporting, and/or change outdated requirements? Please help us with our improvements by providing ideas and input on the following questions:

Question 1: What reporting or other compliance requirements are most burdensome and why?

Question 2: How would you streamline reporting and compliance requirements? (please cite or describe specific examples if you can)

Question 3: What other compliance information are you providing to the federal government outside the procurement process that could be used to reduce duplication?

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2. Procurement Rules and Practices

Campaign 2: Procurement rules and practices - We know entities doing business in the private sector have best practices and we’re anxious to learn about and replicate in the Federal Government wherever possible. We want to hear about innovative approaches to contracting that align with your business practices.

Question 1: What are the most effective ways to encourage innovative offers and best solutions?

Question 2: How can we reduce the cost of transactions for contractors?

Question 3: What are the best ways to improve the efficiency and effectiveness of acquisitions for information technology?

Question 4: What procurement rules or practices are most effective and which are least effective and why?

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3. Small Business Participation

Campaign 3: Participation by small and minority businesses and non-traditional government contractors - We know many businesses lack the resources and expertise to participate in the Federal marketplace. We welcome feedback – especially by entities that are not participating in Federal contracting – to understand what steps we can take to make your participation possible.

We welcome feedback on how to increase participation in Federal contracting.

Question 1: How can we make doing business with the government easier and less costly for small businesses, minority businesses, new entrants, and non-traditional government contractors?

Question 2: If you are a small business, minority owned business, or new entrant, what features of the federal acquisition system are most helpful and which are least helpful to you?

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