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Published Sep 22, 21
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The proposed guideline could indicate that small companies would need to have one employee spend three months a year simply getting in data. Remember, this is data the government currently has but does not collect centrally. While I am all in favor of developing tasks, I do not believe requiring small companies to hire employees to provide data a second time is a worthwhile use of their dollars or tax dollars, due to the fact that somebody has actually got to spend for this.

Information is not totally free. Businesses will decide it is much better to sell independently of GSA, which will enhance the federal government's cost to purchase, or the small companies will drop out of the federal market completely, decreasing competitors. We have already lost over 100 small contractors in the previous 2 years.

I look forward to hearing from our witnesses today about the effects of GSA's proposed guideline and any alternative they would recommend to enhance how the government buys whatever it buys. Thank you, Mr. Chairman, and excellent morning.

The GSA schedules have a variety of advantages for both vendors and buying companies. Most significantly, it produces an easier system that permits contracting officers direct access to the items and services of various firms without the need of releasing numerous solicitations for each requirement. For little companies with restricted resources, relative inexperience navigating the procurement procedure, landing on a GSA schedule can be an important primary step towards securing the federal government as a client.

The guideline requires that firms that hold schedule agreements while other government-wide acquisition contracts report transactional data through an electronic system. While it appears that much of this data is currently available to the GSA, the brand-new rule increases the frequency of reporting and broadens what information firms are required to provide. GSA Search Engine Ranker.

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With that, I thank the witnesses for affirming today, and I yield back. Chairman HANNA. Thank you.

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What the rule needs is month-to-month reports from a range of GSA specialists. This includes both the schedule contractors, along with those who hold IDIQ, indefinite delivery, indefinite amount contractors, and what we call GWACs, Government-wide Acquisition Agreements, to prepare these regular monthly reports of all federal sales made throughout the prior month.

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For those contractors who take part in the pilot program, they will be alleviated from a concern, what we call the price reductions stipulation, which is another compliance clause that remains in GSA agreements. In the public conference that GSA held on April 17th, I attended virtually. My understanding of that meeting is that everybody in the space had issues about the guideline, consisting of GSA's own inspector general.

There is a records that is supposed to be published of that hearing, but I have not yet seen that records. The proposed guideline raises a range of concerns. There are four which I would like to resolve briefly today. The first, which I make certain you will hear from all our panel members about, is the cost of application and compliance.



I would recommend that for some specialists, it will take six hours for them to determine which of their IT systems hold the numerous information components that GSA has required for this rule. That does not permit whenever for developing a report, making sure that the report is accurate, and training its personnel on how they will send that report on a regular monthly basis.

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This might not potentially allow at any time for the specialists to really evaluate the reports to make sure that the data is appropriate. There is absolutely nothing in the proposed guideline that suggests what would take place if the contractors send inaccurate data or if they just remove data due to the fact that it is undoubtedly inaccurate.

The second troublesome area is the possible expansion of what we call business sales practice requirements. GSA professionals are needed to submit business sales practices prior to agreement award and during agreement performance when particular things occur, like if they go to include items to a professional's increased costs. The proposed guideline allows GSA to ask for CSPs at any time (GSA Search Engine Ranker).

This needs professionals to enter into their data systems and look at real discount rates on transactions. I mean, we see news release after news release from the Department of Justice stating that specialists have actually fraudulently supplied this details when in truth they just have not inspected. This is a big issue.

We understand it is going to cost a lot to collect the details, but what is unclear is what benefit GSA is going to receive from the details. And after that finally, is the private and proprietary nature of the information. Transactional information pricing has constantly been safeguarded by the courts under FOIA, and GSA does not appear to value based on comments made at the meeting that this holds true.

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GSA acknowledges the extra reporting requirement will certainly have a cost for affected businesses. SBA's Workplace of Advocacy and GSA's own inspector general kept in mind that estimates in the proposed rule appear significantly understated.

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Intricacy, on the other hand, procedures if a policy modification will make selling to the government harder or easier. Basically, will the federal market be more or less challenging to understand? Or as I typically hear from entrepreneur, am I going to require to hire someone for this? While GSA contents its reporting service will be user- friendly, our experience is that government information systems are anything.

Often, nevertheless, small companies offer customized and innovative options that in combination with competitive rates make for best worth in procurement instead of most affordable rate. While GSA suggests that rates will just be one aspect in determining finest value, it provides considerable weight. The words "rate" or "prices" appear 165 times in the policy, while "finest worth" just appears 7.

This resembles asking sellers selling on Amazon to report to Amazon what it sold on Amazon. This seems to be an inefficient way to gather data. And speaking to the driver behind this regulation, we continue to be worried about a vision of federal government procurement that seeks to categorize personalized services into narrow categories (GSA Search Engine Ranker Services).

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Thank you, Mr. Stanford. Next, we have Mr. Roger Waldron, who is president of the Coalition of Federal Government Procurement. We can break now but I believe we do have time to get through.

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