Open Dialogue on Improving How to Do Business with the Federal Government Browse Recent ideas

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 »

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 »

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 »

Issue: The overly complex, burdensome ordering procedures for the establishment of Blanket Purchase Agreements (BPAs) under the GSA Schedules program. Specifically the preference for multiple award BPAs over single award BPAs. The strong preference of multiple award BPAs undermines the ability of customer agencies to achieve best value outcomes using the GSA Schedules program. It essentially limits the tools in the tool ...more »

Issue: Restrictive experience requirements under the GSA Schedule program. For example, under IT Schedule 70 a company must have been in business for at least two years to be eligible for a contract. The GSA Schedule experience requirements limit access to new, innovation companies providing cutting edge technologies. It is an unnecessary barrier to entry to the federal market place. Recommendation: Eliminate the mandatory ...more »

It would be beneficial if the end users were cognizant of what they were asking vendors to bid on. There have been many "E-Buy" solicitations that we have passed on because tossed into the package of furniture is some oddball piece that locks the bid into a larger firm that will only work with their "preferred" dealers and effectively garnering the entire package. Making it mandatory for the requestor to select product ...more »

Issue: Intellectual property rights as currently set forth in GSA Schedule contracts are unclear, cumbersome and unduly burdensome for contractors. The End User License Agreement (EULA) requirements remain unclear in IT Schedule 70. As such, each license agreement must be reviewed by the contracting officer and legal counsel. Recommendation: A basic set of terms should be developed that identify the key requirements ...more »

If a member of the Chief Acquisition Officers Council has never participated with a contractor in developing a formal proposal in response to a Federal solicitation, each is encouraged to engage one of the Agency contractor’s and ask to observe the (painful and expensive) processes industry goes through to respond to a Federal solicitation, particularly a high dollar value procurement involving submission of a complex ...more »

FBO should list correct Product and Service Codes from the FPDS Manual found at http://www.acquisition.gov/PSC%20Manual%20-%20Final%20-%2011%20August%202011.pdf If the codes could be validated before posting, it would help small businesses locate appropriate opportunities. For example, it would be easier for a roofer to locate a roofing contract if the FBO announcement is coded with a 'Y' or 'Z' designation, instead ...more »

If the USG did not pay for development, it has no skin in the game. Include a presumption under FAR 2.101 that an item is commercial if developed entirely at private expense. Such items can be purchased at firm fixed prices and with no schedule or development risk to the USG. These advantages are undercut, however, if such items cannot be purchased efficiently (or at all). The increased transaction costs and complex ...more »

In section 866 of the 2011 NDAA, Congress authorized a pilot program for the acquisition of Military Purpose Nondevelopmental Items (MPNDI). This allows products developed entirely at private expense to be purchased using streamlined, commercial-like procedures. This gap-filler was carefully “designed to test whether the streamlined procedures similar to those available for commercial items can serve as an effective ...more »

In business, time is money. In war, time is lives. Companies and the warfighter alike are threatened by the glacial pace of current procurement cycles. Purchases that have always taken months now take years. As prominent authorities on policy have noted (citing examples such as unmanned systems and MRAP), the USG often has the most success when bypassing the system entirely: “When it is necessary to go around the ...more »