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HORAN. GSA Search Engine Ranker Services. Well, the method I would like then to figure it out is if it really produces a better value, finest worth to the federal government, thinking about the expense to the contractors. I do not think they can do that based on the way in which the proposed guideline is carried out here.

Small services are known for the added value they can supply firms with advantages such as customer service - GSA SER Services. Mr. GSA Search Engine Ranker Software. Horan, you specified in your testimony that the new guideline does not account for such included value. Once again, that it could be-- the procurement could be driven to low cost only, and as an outcome of that, the professionals who use some of these other terms and services that offer finest worth will lose sales at a minimum, perhaps be driven out of the market.

Due to the fact that they are out of the business or they are just not bidding any longer? Since they are out of the service. Due to the fact that there is such pressure on contracting officers to look at only low cost that in some cases they will leave out factor to consider of finest value but eventually, I believe they could be out of the company.

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The ratio for federal government procurement study in its survey, little businesses suggest that it would take on typical 232 hours to comply with the GSA's proposed guideline. Mr. Stanford, has your business done its own estimate on the hours it will take to comply with the new requirement, and do you discover the results of the study to be more precise than GSA's own analysis? And while we have looked at their study and the ABA work, we are likewise encouraged in accepting their conclusion because likewise SBA Workplace of Advocacy and GSA's own inspector general determined that those expenses appear understated.

Mr. TAKAI. Okay. Besides our spin on compliance, can you discuss some other costs that companies like yours will need to face because of this guideline? Mr. STANFORD. I will not speak with our business individually, however speaking to the business we work with as they enter the federal market, the expenses beyond compliance are-- for little businesses are initial costs up front.

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Mentioning the cost of updating its information systems, GSA is proposing to ask suppliers to report to GSA the details of what was bought through GSA. This resembles asking retailers selling through Amazon to report to Amazon what it offered, through Amazon. To take this example one action even more, Amazon would then use that info to advertise rates to other customers, on Amazon.

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While not a perfect comparison, GSA in lots of ways operates as an Amazon-like part of the acquisition procedure. The intent behind this rule is looking for to make a best-in-class contracting market. GSA has chosen to pass on investing in a data collection system that might collect this information immediately.



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II. The Guideline Enforces a Considerable, Underestimated, and Unnecessary Concern GSA estimates that it will take 6 hours for a specialist to accomplish all tasks required to comprehend the reporting requirements, prepare its systems and workers, and establish the treatments essential for producing the needed reports, and an average 31 minutes monthly for continuous reporting. 2 GSA does not provide adequate information to analyze how these estimates are flawed, however essentially every notified party who has weighed in on these quotes believes they are incorrect.

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Reg. 11625.

Otherwise, the specialist will run the risk of a claims of fraud under the False Claims Act, as has been the case with basically every other kind of price or expense reports submitted by a contractor to the government. Importantly for this hearing, small services will bear the largest part of this burden-- GSA approximated that out of 15,738 suppliers holding agreements that would be subject to this Rule, 12,590 are little businesses (GSA SER Services).

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Reg. 8 GSA also recognizes a point extremely crucial to industry-- that rate paid is just of many "details points"in figuring out the finest worth to the government. 10 We can also add client service, item support services, service warranty, and other terms to this list.

According to GSA's own analysis, this problem enforced on contractors will supply the government with only one of the essential info points-- transactional cost-- without any means to acquire the other details points essential to examine price. Without access to, and consideration of, this other important information, the cost information is of little worth at finest and can be very misleading at worst.

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In my view, the failure of the Rule to record these other non-price aspects could be especially hazardous to small companies. Small companies often operate as value-added resellers or otherwise differentiate themselves in the competitive market based upon the worth they add to a transaction, such as client and product service capability, that is not captured by deal rate.

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