Issue: Extensive data collection requirements via the Federal Acquisition Regulation combined with an explosion in data reporting for agency specific procurement programs and the Federal Strategic Sourcing Initiative (FSSI). These data reporting requirements are increasing costs and risks for contractors across the federal procurement enterprise. Costs that are ultimately borne by customer agencies through higher prices ...more »
2. Procurement Rules and Practices
Issue: Contract Duplication. Across the federal enterprise there has been an explosion in the number of multiple award IDIQ contracts for the same or similar services. Contract duplication increases bid and proposal and administrative costs for customer agencies and contractors. Contractors are compelled to compete for contracts for fear of being locked out of a market. At the same time there are many IDIQ contracts ...more »
3. Small Business Participation
Issue: Reform the MAS Pricing Policies. Specifically, eliminate the Price Reduction Clause (PRC), GSAR Clause 552.238-75. The current MAS pricing policies do not reflect current practices in the commercial market place. The pricing policies are inconsistent with the statutory and regulatory mandates for competition at the order level. The increased transactional and contract administration costs for compliance with the ...more »
3. Small Business Participation
Issue: Extensive data collection requirements via the Federal Acquisition Regulation combined with an explosion in data reporting for agency specific procurement programs and the Federal Strategic Sourcing Initiative (FSSI). These data reporting requirements are increasing costs and risks for contractors across the federal procurement enterprise. Costs that are ultimately borne by customer agencies through higher prices ...more »
2. Procurement Rules and Practices
Over the last decade, the number of laws, regulations and provisions that apply to commercial item have dramatically increased. For example, in 1996 under 52.212-5(b) there were 17 provisions of law or executive orders identified as applicable to commercial item contracts. In 2012, the number has climbed to 51. The resulting explosion of statutes and regulations applicable to commercial item contracting increases complexity, ...more »
3. Small Business Participation
Over the last decade, the number of laws, regulations and provisions that apply to commercial item have dramatically increased. For example, in 1996 under 52.212-5(b) there were 17 provisions of law or executive orders identified as applicable to commercial item contracts. In 2012, the number has climbed to 51. The resulting explosion of statutes and regulations applicable to commercial item contracting increases complexity, ...more »
Each site visited has unique registration, password requirements and required company data. Cumbersome and redundant. While it is understandable that agencies are different and data base information is not shared, some intra agency information is not shared from one platform to the next. There needs to be a Clearing House for each Agency and from there a sharing agreement between agencies.
2. Procurement Rules and Practices
The FAR needs a top to bottom scrubbing as well as some thought as to how its utility could be improved. Many sections of the FAR were developed years ago or pieced together from predecessor regulations dating back to the 60s when Federal procurement was supply-focused. Other sections of the FAR are a patchwork of concepts that, while "politically correct" at inception, no longer suit the needs of modern procurement and ...more »
3. Small Business Participation
When we started our business as an 8a, even as former military acquisition professionals, we encountered so much "red-tape" in getting on the GSA Schedule that we eventually had to hire a company to assist us in the process. 8 months and $15K later, we finally got onto the IT Schedule 70. Instead of being easy for the small company, it was hard, and expensive. I have talked to other companies who did not have the time ...more »
2. Procurement Rules and Practices
One possible solution to reduce the complexity associated with commercial item acquisition would be to address the burden of providing Commercial Sales Practices ("CSP") information in response to large contract solicitations (e.g. FSS, VA National Contract, DHA E-CAT). While we acknowledge that CSPs may be helpful to enable the determination of fair and reasonable pricing, the nature and type of data requested varies ...more »
2. Procurement Rules and Practices
The FAR currently contemplates two solutions to resolve the impact of corporate acquisitions and/or reorganization on federal contractors under the Anti-Assignment Act: the Novation process and a Name Change agreement. We propose that a third avenue be established to address situations in which, due to internal restructuring, the legal entity has changed but the parent company remains the same. In these instances, ...more »
3. Small Business Participation
Contracting Officers/Specialists get comfortable processing set aside contracts of a particular type. Some are more comfortable with the WOSB program versus SDVOSB or HUBzone and naturally gravitate towards what they know. We continually face the comment of "if you bring me an 8(a), I can make this happen quickly but I can't give you an estimate for how long it may take otherwise" SBA has an incomplete set of practical ...more »