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I hope the GSA will either desert this technique and begin over or seriously revamp the rule prior to it becomes last. This is a problem the Subcommittee will be keeping track of and will continue to keep an eye on, and we anticipate having another opportunity to consult with you if that is very important.

Without objection, so purchased. 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 AVAILABLE IN TIFF FORMAT] 1. Intro Mr. Chairman and Members of the Committee, my name is Sheila Armstrong.

The Proposed Guideline does not apply to VA --------------------------------------------------------------------------- FSS agreements in the pilot program. GSA grossly undervalues both implementation costs and compliance costs of transactional data reporting.

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Third, it does not appear that GSA is specific how it will utilize the large quantity of data that it seeks to gather under the Proposed Rule, however the potential for down rates pressure that likely will result from transactional data reporting might have an out of proportion result on small companies who hardly ever win a "race to the bottom" on rates.

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Line item rates has long been exempt from disclosure under the Flexibility of Info Act (FOIA) due to its private and exclusive nature. This data also is secured from disclosure under the Trade Secrets Act. II. Select Congress Regarding the Proposed Transactional Data Guideline A. Approximated Implementation and Reporting Costs of the Transactional Data Rule GSA estimates that the general public reporting concern for its specialists to initially set up systems for transactional information reporting at six hours. 2 This approximated 6 hours includes "the time for examining directions, searching existing data sources, event and maintaining the data required, and completing and evaluating the collection of info" as well as "training, compliance systems, settlements, and audit preparation the new stipulation may require." 3 GSA estimates that the month-to-month burden afterwards will balance 4 roughly 0.

e - GSA SER. sales) and presumes regular monthly reporting concern increases with supplier sales based upon the distribution of sales and obligations within FSS agreements and non-FSS agreements." 6 What GSA permits no time at all for is system enhancements that may be required ought to GSA choose to alter the fields of information to be reported as it would deserve to do upon 60 days notification under the Proposed Guideline. 7 In addition, these price quotes of six hours for initial set-up and 31 minutes each month for ongoing reporting are grossly undervalued.

9 This price quote likewise includes the effort that GSA prepares for specialists will be required to make to set up modifications to professional training, compliance systems, settlements, and audit preparation-- and probably consists of the time and expense required to customize information- event, reporting, and information-technology (IT) systems to properly and efficiently report the information needed by the Proposed Rule. 10 GSA's own Inspector General's workplace acknowledges that contractors likely will spend far more than 6 hours to set up business systems for transactional information reporting. 11 As the GSA Office of Inspector General keeps in mind in its remarks to the Proposed Rule: --------------------------------------------------------------------------- 8 Id.

Given this, we question whether GSA's quote of 6 hours per contractor to configure their --------------------------------------------------------------------------- systems for reporting is precise - GSA SER Software. 12 12 Id. This 6 hour estimate need to assume that all data fields reside in the very same IT system and that the report can be established by a single person without consultation with others inside or outside the company.

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In many cases, the systems that house the numerous fields GSA is requesting in its month-to-month report are not set approximately interact with one another. Appropriately, some specialists will require to by hand assemble the information needed for transactional information reporting, or might need to upgrade their IT systems in --------------------------------------------------------------------------- order to comply (GSA SER Services).

For some specialists, especially small companies, establishing systems to record and report transactional data may involve assessment with professionals outside the company at hourly rates consequently increasing the costs to the contractor. These approximated costs are not factored into GSA's 6 hour quote for established. 13 --------------------------------------------------------------------------- 13 As kept in mind in the ABA's Remarks to the Transactional Data Rule: The Area recommends that the hours needed will in reality be much greater.

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Many professionals may need substantial changes or upgrades to organization systems in order to provide the data looked for by GSA in a form that will permit significant and accurate pricing comparison as meant. The fields needed by GSA for transactional-data reporting may not live in the very same IT system; couple of accounting systems consist of both producer part number and contractor part number in the exact same system when those part numbers differ.

g., materials management) to meet the requirements of the Proposed Rule. These and other required modifications would require coordination amongst functions such as the contractors' IT departments and change management groups along with responsible executives. The time needed simply to search for, extract, evaluation, and test such information, and carry out system modifications, will well surpass six hours.

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Additionally, the estimated 31 minutes per month does not include any time enabled ongoing upkeep of data, consisting of but not limited to modifications by GSA to the data fields needed as allowed by the Proposed Rule. 14 Provided the unidentified ramifications on a professional should it supply information to GSA that is inaccurate or incomplete, contractors will require to evaluate the transactional data prior to submission which could take hours relying on the size of the contract.

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B. GSA's Proposed Growth of Commercial Sales --------------------------------------------------------------------------- Practice Disclosure Requirements is Unduly Burdensome All GSA professionals should prepare and send CSPs prior to award and at particular key times throughout efficiency of a GSA agreement. When a professional looks for to increase prices or add products to the contract GSA requires either brand-new CSPs, or a statement from the specialist that the CSPs have not changed because the time they were last submitted.

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Due to the prospective financial risks produced by incorrect CSP disclosures, contractors need to invest substantial time examining sales data and preparing present, precise and total CSPs when they are needed to do so (GSA SER). Even a declaration that the CSPs have actually not changed needs substantial review of transactional sales data to validate that this statement is correct at the time that it is made.

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