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

Little services are known for the included value they can supply companies with advantages such as client service - GSA SER. Mr. GSA Search Engine Ranker Services. Horan, you specified in your statement that the new rule does not account for such added worth. Once again, that it might be-- the procurement could be driven to low cost only, and as an outcome of that, the specialists who provide some of these other terms and services that supply best worth will lose sales at a minimum, maybe be driven out of the market.

Due to the fact that they are out of the service or they are just not bidding anymore? Since they are out of the company. Because there is such pressure on contracting officers to look at just low price that in some cases they will omit factor to consider of finest value but eventually, I think they could be out of the company.

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The ratio for government procurement study in its survey, little organizations indicate that it would take on typical 232 hours to comply with the GSA's proposed guideline. Mr. Stanford, has your organization done its own quote on the hours it will take to comply with the brand-new requirement, and do you discover the outcomes of the study to be more accurate than GSA's own analysis? And while we have actually looked at their study and the ABA work, we are also encouraged in accepting their conclusion since also SBA Office of Advocacy and GSA's own inspector basic identified that those costs seem downplayed.

Other than our spin on compliance, can you go over some other expenses that business like yours will have to deal with due to the fact that of this guideline? I will not speak to our company individually, but speaking to the business we work with as they enter the federal market, the expenses beyond compliance are-- for small organizations are initial costs up front.

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Pointing out the expense of updating its data systems, GSA is proposing to ask vendors to report to GSA the details of what was bought through GSA. This is like asking retailers offering through Amazon to report to Amazon what it offered, through Amazon. To take this example one action further, Amazon would then use that info to market prices to other customers, on Amazon.

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While not an ideal contrast, GSA in lots of methods operates as an Amazon-like part of the acquisition procedure. The intent behind this guideline is seeking to make a best-in-class contracting marketplace. Yet, GSA has actually chosen to hand down buying an information collection system that might gather this details immediately.



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II. The Rule Enforces a Considerable, Underestimated, and Unnecessary Problem GSA estimates that it will take 6 hours for a contractor to achieve all tasks required to comprehend the reporting requirements, prepare its systems and workers, and establish the treatments necessary for creating the needed reports, and a typical 31 minutes monthly for continuous reporting. 2 GSA does not supply sufficient detail to analyze how these estimates are flawed, however virtually every notified celebration who has weighed in on these quotes thinks they are inaccurate.

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Reg. 11625. The Small Company Administration's Workplace of Advocacy reports that little organizations and their representatives are worried that GSA "under quotes the burden and resources." 3 The Council of Defense and Space Market Associations sees the price quotes as "grossly ignored,"as stopping working to "account for expensive modifications to information systems that will be required to properly and totally catch the data elements needed by the rule"or to "sufficiently represent the time needed to perform quality assurance on draft submissions and investigation into possible data abnormalities that frequently arise with transactional data reporting." 4 Based on its experience with pre-award audits of contractor systems, the GSA Workplace of Inspector General "concern [s] whether GSA's estimate of 6 hours per professional to configure their systems for reporting is accurate"and "compete [s] the projected burden of regular monthly reporting as 0.

Otherwise, the contractor will run the risk of an allegation of scams under the False Claims Act, as has been the case with essentially every other type of rate or expense reports sent by a contractor to the federal government. Significantly for this hearing, little businesses will bear the largest part of this problem-- GSA approximated that out of 15,738 vendors holding contracts that would be subject to this Rule, 12,590 are small companies (GSA SER Services).

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Reg. 11625. III. The Anticipated Benefit is Badly Defined, and Not --------------------------------------------------------------------------- Likely to be Realized GSA prepares for that the transactional data will "improve GSA's capability to perform significant rate analysis and more efficiently and successfully validate reasonable and reasonable pricing"on its agreements and will permit government buyers "to compare rates prior to positioning orders." 8 GSA also acknowledges a point very crucial to industry-- that price paid is just of numerous "info points"in determining the very best worth to the federal government. 9 Similarly essential are other factors to consider, "such as overall cost, desired performance levels, shipment schedule, special terms, time factors to consider, and consumer fulfillment." 10 We can likewise add customer care, product assistance services, service warranty, and other terms to this list (GSA SER Services).

According to GSA's own analysis, this concern imposed on contractors will provide the federal government with just one of the essential details points-- transactional rate-- without any methods to acquire the other information points necessary to assess cost. Without access to, and consideration of, this other important details, the cost info is of little value at finest and can be really misleading at worst.

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In my view, the inability of the Rule to record these other non-price factors could be particularly hazardous to small companies. Small companies often operate as value-added resellers or otherwise distinguish themselves in the competitive market based on the value they include to a transaction, such as customer and item service ability, that is not recorded by transaction cost.

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