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I hope the GSA will either desert this technique and begin over or seriously revamp the guideline prior to it ends up being last. This is a concern the Subcommittee will be keeping track of and will continue to keep an eye on, and we look forward to having another chance to meet you if that is essential.

Without objection, so ordered. This hearing is now adjourned. And thank you again. [Whereupon, at 11:33 a. m., the Subcommittee was adjourned.] A P P E N D I X [GRAPHICS NOT READILY AVAILABLE IN TIFF FORMAT] 1. Intro Mr. Chairman and Members of the Committee, my name is Sheila Armstrong.

The Proposed Rule does not apply to VA --------------------------------------------------------------------------- FSS contracts in the pilot program. The issues with the Proposed Guideline are lots of. The four that I am going to talk about today are especially relevant to little businesses. Initially, GSA grossly ignores both execution costs and compliance costs of transactional information reporting.

How to use Xrumer to find foot prints for GSA Search Engine RankerThird, it does not appear that GSA is specific how it will utilize the large amount of data that it seeks to gather under the Proposed Rule, but the capacity for downward pricing pressure that likely will arise from transactional data reporting might have a disproportionate result on small services who hardly ever win a "race to the bottom" on prices.

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This data likewise is safeguarded from disclosure under the Trade Secrets Act. Select Congress Concerning the Proposed Transactional Data Guideline A. Approximated Execution and Reporting Costs of the Transactional Data Rule GSA estimates that the public reporting concern for its professionals to initially set up systems for transactional information reporting at six hours. 3 GSA approximates that the monthly concern thereafter will balance 4 around 0.

e - GSA SER Services. sales) and assumes monthly reporting problem increases with supplier sales based upon the circulation of sales and responsibilities within FSS agreements and non-FSS agreements." 6 What GSA enables no time for is system improvements that might be needed ought to GSA elect to change the fields of information to be reported as it would can do upon 60 days notice under the Proposed Rule. 7 In addition, these price quotes of 6 hours for preliminary set-up and 31 minutes monthly for continuous reporting are grossly ignored.

Reg. 11625. 3 Id. 4 GSA approximates a range of two minutes (for specialists with $0 in sales) and 4 hours (for professionals with higher than $50 million in sales). See id. 5 Id. 6 Id. 7 Id. at 11628. 1. Initial Set-Up Likely Will Far Surpass 6 --------------------------------------------------------------------------- Hours GSA estimates that its specialists will spend around 6 hours to set up its systems to produce the monthly report needed by the Transactional Data Guideline. 8 This six-hour quote consists of the time that GSA price quotes will be needed for reviewing guidelines, browsing existing databases and other sources of info, and event and reviewing the gathered info. 9 This price quote likewise consists of the effort that GSA anticipates professionals will be needed to make to set up changes to contractor training, compliance systems, settlements, and audit preparation-- and most likely consists of the time and expenditure required to modify information- event, reporting, and information-technology (IT) systems to precisely and efficiently report the information required by the Proposed Rule. 10 GSA's own Inspector General's office acknowledges that contractors likely will invest even more than six hours to establish organization systems for transactional data reporting. 11 As the GSA Workplace of Inspector General keeps in mind in its comments to the Proposed Guideline: --------------------------------------------------------------------------- 8 Id.

Provided this, we question whether GSA's estimate of 6 hours per professional to configure their --------------------------------------------------------------------------- systems for reporting is accurate - GSA SER Services. 12 12 Id. This six hour price quote must presume that all data fields reside in the very same IT system which the report can be set up by a single person without consultation with others inside or outside the company.

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In most cases, the systems that house the numerous fields GSA is asking for in its month-to-month report are not set as much as interact with one another. Appropriately, some professionals will need to manually assemble the information needed for transactional data reporting, or might require to upgrade their IT systems in --------------------------------------------------------------------------- order to comply (GSA SER).

For some contractors, especially little organizations, setting up systems to capture and report transactional data might involve assessment with experts outside the business at hourly rates thus increasing the costs to the contractor. These approximated costs are not factored into GSA's 6 hour quote for established. 13 --------------------------------------------------------------------------- 13 As noted in the ABA's Comments to the Transactional Data Guideline: The Section suggests that the hours needed will in fact be much higher.

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Many specialists might need significant modifications or upgrades to service systems in order to supply the information sought by GSA in a form that will enable significant and accurate rates comparison as meant. For instance, the fields required by GSA for transactional-data reporting may not reside in the same IT system; couple of accounting systems include both maker part number and contractor part number in the exact same system when those part numbers vary.

g., materials management) to satisfy the requirements of the Proposed Guideline. These and other required changes would require coordination amongst functions such as the professionals' IT departments and alter management teams as well as responsible executives. The time needed just to search for, extract, evaluation, and test such data, and execute system adjustments, will well exceed six hours.

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Additionally, the approximated 31 minutes per month does not consist of any time allowed for continuous maintenance of data, including but not restricted to modifications by GSA to the information fields required as allowed by the Proposed Rule. 14 Given the unidentified ramifications on a contractor should it offer information to GSA that is incorrect or insufficient, contractors will require to examine the transactional information prior to submission which might take hours relying on the size of the contract.

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--------------------------------------------------------------------------- 14 80 Fed. Reg. 11628. B. GSA's Proposed Growth of Commercial Sales --------------------------------------------------------------------------- Practice Disclosure Requirements is Unduly Difficult All GSA contractors should prepare and submit CSPs prior to award and at certain crucial times throughout efficiency of a GSA agreement. When a specialist seeks to increase rates or add items to the agreement GSA needs either new CSPs, or a statement from the professional that the CSPs have actually not changed because the time they were last submitted.

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Due to the prospective financial dangers produced by unreliable CSP disclosures, professionals need to spend significant time reviewing sales information and preparing present, accurate and total CSPs when they are required to do so (GSA Search Engine Ranker Software). Even a declaration that the CSPs have actually not changed requires substantial evaluation of transactional sales information to validate that this declaration is correct at the time that it is made.

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