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Published Aug 04, 21
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Mentioning the cost of updating its data systems, GSA is proposing to ask suppliers to report to GSA the information of what was acquired through GSA. This is like asking sellers selling through Amazon to report to Amazon what it sold, through Amazon. GSA Search Engine Ranker Services. To take this example one action even more, Amazon would then use that information to advertise rates to other consumers, on Amazon.

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While not a best comparison, GSA in many ways operates as an Amazon-like part of the acquisition procedure. Asia Virtual Solutions. The intent behind this guideline is looking for to make a best-in-class contracting marketplace. Yet, GSA has chosen to hand down investing in a data collection system that could gather this info instantly.

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II (GSA Search Engine Ranker Services). The Rule Enforces a Significant, Underestimated, and Unnecessary Concern GSA estimates that it will take six hours for a contractor to achieve all tasks needed to comprehend the reporting requirements, prepare its systems and personnel, and develop the treatments needed for producing the needed reports, and a typical 31 minutes each month for continuous reporting. GSA SER Software. 2 GSA does not supply enough information to analyze how these price quotes are flawed, but essentially every notified party who has weighed in on these price quotes thinks they are incorrect.

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Reg. 11625. The Small Business Administration's Workplace of Advocacy reports that small companies and their representatives are concerned that GSA "under estimates the problem and resources." 3 The Council of Defense and Area Market Associations views the estimates as "grossly undervalued,"as failing to "represent expensive adjustments to info systems that will be needed to accurately and completely capture the data components required by the rule"or to "sufficiently account for the time needed to carry out quality assurance on draft submissions and examination into prospective data anomalies that often emerge with transactional data reporting." 4 Based upon its experience with pre-award audits of professional systems, the GSA Office of Inspector General "concern [s] whether GSA's price quote of 6 hours per specialist to configure their systems for reporting is accurate"and "contend [s] the predicted burden of monthly reporting as 0.

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Otherwise, the professional will run the risk of an accusation of scams under the False Claims Act, as has actually held true with basically every other type of rate or cost reports submitted by a professional to the government. Significantly for this hearing, little services will bear the biggest part of this burden-- GSA approximated that out of 15,738 vendors holding contracts that would be subject to this Rule, 12,590 are little organizations. GSA SER Services.

Reg. 11625. III. The Anticipated Advantage is Poorly Specified, and Not --------------------------------------------------------------------------- Likely to be Recognized GSA expects that the transactional information will "improve GSA's capability to conduct meaningful price analysis and more effectively and successfully validate reasonable and sensible pricing"on its agreements and will permit federal government purchasers "to compare costs prior to positioning orders." 8 GSA likewise acknowledges a point really important to industry-- that cost paid is only of numerous "details points"in figuring out the very best worth to the government. 9 Similarly essential are other considerations, "such as overall cost, desired performance levels, shipment schedule, unique terms, time factors to consider, and client complete satisfaction." 10 We can also include consumer service, item support services, service warranty, and other terms to this list.

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So, according to GSA's own analysis, this burden enforced on professionals will offer the federal government with just one of the needed information points-- transactional cost-- with no ways to acquire the other details points needed to examine cost. Without access to, and factor to consider of, this other essential information, the rate details is of little value at finest and can be extremely deceptive at worst.

In my view, the failure of the Guideline to record these other non-price aspects might be particularly harmful to small companies. Small businesses often operate as value-added resellers or otherwise distinguish themselves in the competitive market based upon the value they include to a deal, such as customer and product service ability, that is not recorded by transaction cost.

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