Just GSA

GSA seeks customer satisfaction feedback - let's hope they act on the results...

Well, it's always good to have a customers evaluate your performance, so I'm pleased to see that GSA is interested in such.  While GSA's survey originated before the election of President Obama, change is still forthcoming.  By the way, ALL GSA new offerors are required to submit a completed Open Ratings Customer Satisfaction Report, which natuarally, rarely has negative comments.

I sincerely hope that GSA management reviews and actually implements changes based on the survey results rather than a federal SES official simply checking the survey off as a completed process for their annual performance review.

Per the e-mail survey, the "General Services Administration (GSA) is deeply committed to better meeting your needs and those of the vendor community as a whole. In support of this goal, a survey is being conducted to measure your satisfaction with the Procurement Contracting Officer (PCO) and contract award/mod process.

CFI Group, an independent satisfaction research and consulting firm, is administering this survey. Your responses will remain completely confidential and your identity will not be revealed to GSA unless desired. The survey is conducted via a secure server and is authorized by Office of Management and Budget Control No. 1505-0191.

Because it makes them "feel good"

Why else would GSA create ANOTHER GSA schedule* (now up to 44 GSA schedules) just to cover "Green Support Services" other than to "feel good", like Prius owners, who's gas savings dwarf their increase in car insurance.  These services could have and should have been added to GSA Schedule 899 for Environmental Services by simply creating a new Special Item Number.

* GSA creates contract for 'green' support serviceshttp://www.fcw.com/online/news/154231-1.html/?s=dailyNL_10_30
FCW, 10-29-08

The General Services Administration said today it created a new Multiple Award Schedule contract vehicle to provide energy-management support services for agencies. The vehicle seeks to help agencies comply with a presidential executive order to strengthen environmental, energy and transportation conservation goals, the agency said.

Executive Order 13423, which President Bush signed last year, sets goals for agencies in energy efficiency, renewable energy, recycling, sustainable buildings, electronics stewardship and water conservation. The order also requires that agencies use environmental management systems as the framework for managing and continually improving those sustainable practices.

“EO 13423 was a tremendous step toward environmental responsibility governmentwide,” said Tyree Varnado, acting commissioner of GSA’s Federal Acquisition Service. “At GSA, we continue to strive to make it easier for all government agencies to comply.”

GSA’s affiliated contractors can provide the services and expertise agencies need to develop energy management in government buildings, ranging from preliminary energy audits to comprehensive, full-service energy-management solutions, Varnado said.

GSA Advantage - When does a 24% increase = 1.59% in Sales?

While the Federal Computer Week link www.fcw.com/online/news/154044-1.html states that GSA Advantage (GSA Online Web Purchasing site) sales increased 24% last year, they failed to state that they only represented a mere 1.59% of all GSA sales in FY 2007 ($35.2 billion).

 

GSA Advantage sales has always been anemic and will continue to be such until GSA improves the uploading and approval process.  Currently, GSA Advantage data is at least 30-45 days old as it typically takes GSA 21-30 days to approve a mod request, GSA awardees are required (but most don't) to post any approved mods five days after approval and then GSA CO's can take anywhere from a day to a week+ to approve the mod/upload data.

 

GSA Advantage is best suited to validate that a firm holds a GSA schedule and which manufacturers are approved but ill suited for current and accurate part #'s and pricing.  Also, most CO's who place GSA Advantage orders have to modify their orders (costly and time consuming), as quite often there has been a price decrease, an occasional price increase or sometimes the product is no longer available.

New office will manage schedules contracts/Will Oversight work??

Well, I hope the new GSA oversight office runs better than the oversight committee that was responsible for managing Fannie Mae and Freddie Mac (we know said committee misrepresented their financial status to congress and that lobbyists contributed to the congress election campaigns).  At least, all of the former Fannie Mae and Freddie Mac lobbyists were fired this week.

I feel confident that many benefits will come from the new GSA oversight office, as Robert Bourne will be the MAS Program Office director (formally the Deputy Director of the IT Schedule 70 program). Whenever I had challenges with a schedule 70 offer, Mr. Bourne was always willing and able to intervene to satisfy all parties; Perhaps Mr. Bourne could fix some of the mess of the financial mess in congress,in his spare time.

New office will manage schedules contracts

www.fcw.com , 10-1-08

The General Services Administration today announced that a new office will oversee its Multiple Award Schedules (MAS) program, a major program in the procurement agency.

The MAS Program Office will develop and put into practice acquisition policy and guidance regarding its MAS contracts, GSA said. The office will define shared systems requirements and coordinate ways to improve the program, the agency also said.

According to the charter that formed the new office, the Federal Acquisition Service’s Acquisition Management Office will head the program office to apply consistent rules across more than 17,000 contracts. The program office will strategically align the overall the MAS Program, which is housed under several different offices in FAS, GSA said.

Those FAS business offices still will control the schedules contracts in their scope. The General Supplies and Services, Integrated Technology Services, and Travel, Motor Vehicle, and Card Services will keep management control and operational responsibility of their respective contracts, GSA said.

The MAS Program Office will work with those offices and the Veterans Affairs Department through a governance council.

“I am confident that the MAS Program Office will ensure that the Multiple Award Schedules program remains the government’s preferred acquisition vehicle for commercial products, services and solutions,” said Barney Brasseux, GSA’s deputy administrator. “The new program office is a key accomplishment that will enhance our customers’ ability to meet their mission critical requirements.”

The office’s charter was signed in July by Jim Williams, who was then FAS commissioner and is now GSA’s acting administrator. Robert Bourne is the MAS Program Office director. 

Schedules contract sales increased to $36 billion in fiscal 2007 from $35.2 billion in fiscal 2006, according to figures from GSA.

Doan is done

http://www.fcw.com/online/news/152393-1.html

http://www.washingtonpost.com/wp-dyn/content/article/2008/04/30/AR2008043001271.html?nav=rss_email/components

Well, Ms. Lurita Doan's resignation (GSA Administrator) was expected long ago but some people won't quit under pressure (Mayor of Detroit, US Senator Larry E. Craig, etc), until forced out of office.  Who knows why the White House waited so long....

Doan - GSA seeks advice on schedule program...

While it sounds nice (new advisory panel to begin an in-depth review of the General Services Administration’s policies and regulations for schedule contracts) http://www.fcw.com/online/news/152271-1.html,  I'm pessimistic of any  substitutive  recommendations by 15 acquisition experts ever being implemented. 

I also question the benefits of a two-year panel.  How about a two-day off-site session next month? Why wait two-years?  By that time, we'll undoubtedly have a new GSA Administrator with their own initiatives.
Why having auditor clones is unlikely, it would be nice to have some common expectations by the auditors.  While the auditors have their GSA Report Card to follow, each seems to have their own agenda and determination to find fault. 

I find it absurd that "serious concerns exist" if a GSA contractor has a negative determination to one of the first ten questions on a GSA Report Card http://vsc.gsa.gov/casi/New_Casi.pdf.   So, since when is receiving a 90% satisfactory report generate concerns?

GSA pricing policy could get the boot

Per, Federal Computer Week's article "GSA pricing policy could get the boot" http://www.fcw.com/online/news/152288-1.html, a new advisory panel will determine the fate of a price reduction clause that requires companies on General Services Administration schedule contracts to match discount exceptions made to the class or classes of customers as negotiated in their Final Proposal Revision that are below their GSA rates.

GSA has always required offerors to be "most advantageous" (not defined), as well as being equal to or better than their most-favored customer (not defined either but should be restricted to end-user customers who used the products/services themselves vs. distributors, VARS, dealers or OEM's). 

The price reduction clause does not state any quantity or time frame to invoke the price reduction clause.  My position, is that the discounts and/or concessions made beyond those negotiated with GSA made to the class(es) negotiated under the price reduction clause need only be matched during the overlapping period of performance.  For example, a commercial customers receives a 2% better price for an item and the order is received on Monday and ships out on Tuesday.  GSA should only be granted the additional 2% improvement from the GSA price if an authorized federal ordering activity ordered the same product  on Monday or  before being shipped out on Tuesday.   Many years ago, if an improved price or concession was made to a  federal agency,  GSA holders had to offer the same price/concession to all federal GSA ordering activities for the next 30 days.

I doubt there will be any substantive change to the price reduction clause, as it ensures GSA is continuing to receive pricing and concessions made by GSA holders throughout the life of the contract (5-20 years) vs. their commercial customers.

Sun and Senator Grassley

Per FCW article http://www.fcw.com/print/11_33/news/90256-1.html, it was determined during Sun's option to extend their GSA schedule for five-years that Sun had offered better discounts to some customers their GSA pricing. 

First, this is clearly acceptable behavior and occurs everyday with any large corporation like Sun.  Under the price monitoring clause of Sun's negotiated class(es) of customers in their Final Proposal Revision (Basis of Award), Sun is required to pass along any favorable pricing/concessions if the item is on their schedule and is sold during the same time as any GSA order.  While Sun can and likely indicated in the CSP's for their renewal that they have deviated from their stated business practices, all they needed to provide is  (1) a discussion of the situations that lead to deviations from standard practice, (2) an explanation of how often they occur, and (3) the controls you employ to assure the integrity of your pricing.

 

Sun refused to provide additional historical pricing/concessions to GSA and they became a deadlock.  I know two GSA CO's who refused to sign the Sun GSA extension and the third did so quickly that it was highly suspect.  Amazingly, the signing CO said she was under no pressure to sign the award but she no less was given a bonus for such (boy, that stinks) and she quickly transferred to another government office out of state.  The two non-signing CO's moved into other GSA schedule centers.

 

If GSA wasn't so concerned about losing a big chuck of their Industrial Funding Fee from Sun's GSA sales or if Sun wasn't a big fish, no GSA CO would have tolerated Sun's behavior.  Soon after Sun's GSA extension, they terminated their schedule for convenience but there's talk that their business practices may be investigated, which is allowable for up to three years after a GSA schedule expires/cancelled/terminated.

GSA's long reach overextended

In reference to this blog,

http://blogs.govexec.com/techinsider/archives/2007/11/gsas_long_reach.php.

 

CapITal Reps has been a GSA consulting practice since 1996.  We always require/provide/submit Commercial Sales Practices (CSP's) from any manufacturer being proposed to any GSA schedule, along with the CSP's of the schedule offeror/holder (dealer/reseller).  While we've had rare requests by GSA CO's over the years for the distributor's CSP's, we've always kindly stated that they're irreverent and that was the end of the request.

While GSA auditors are certainly non-standard in their GSA compliance reviews of our clients, they commonly focused on proper Industrial Funding Fee (IFF) capture and reporting, trade compliance, price reductions and occasionally if our client triggered their automatic price reduction clause (the auditor rarely is aware of which class(es) of customers was selected in our clients Final Proposal Revision (Basis of Award) and too often our clients have forgotten.

The cited DoD memo dated Nov 7, 2007 is way off base with requiring Ingram to provide their costs information, if it is the basis of a request by the GSA IG.

First, Ingram is rarely the "exclusive" distributor of any mfg product line.  Even if Ingram was an exclusive distributor, having CSP's from the mfg and offerer/reseller and quick market research always results in a fair and reasonable pricing determination.  In fact, since May 15th, 2007, the GSA Schedule 70 program requires all new mfg adds to include in the proposed pricing matrix the lowest GSA price.

Second, Ingram's GSA mfg Letter of Supply packages are the best offered by any distributor and they either include the mfg's CSP's or state that they are on file with a specific CO at GSA.

Third, the primary purpose of a mfg's CSP is for GSA to determine if the stated discounts and/or concessions stated for the given class of customer that my client/reseller is (Dealer/Reseller/VAR/SI) matches those indicated in my clients spreadsheet matrix.  We often catch this simply mistake.

The GSA IT Schedule 70 solicitation FCIS-JB-980001B, Refresh 21, clause E.6 states that cost and pricing data is not required and states that the CO "may" require additional supporting information, but only to the "extent necessary to determine whether the prices offered are fair and reasonable".  GSA can easily and always determine price reasonableness with CSP's from the mfg, the GSA resellers CSP's and market research and therefore it is unwarranted to request any cost information from Ingram. 

Also, armed with the mfg's CSP's, it's clear what Ingram's discount/cost is and not too hard to determine their markup to our clients (dealer cost/Ingram mfg discount).

The DoD memo states that FAR 15.402 requires CO's must obtain cost information, when there is no other basis for determining that the proposed prices are fair and reasonable (e.g. through market research and price analysis techniques).  While FAR 15.402 is not incorporated by reference into the schedule 70 solicitation, I fully agree that any CO should not award products/services to a GSA schedule without fair and reasonable price determination (e.g.  CSP's from the mfg and reseller and comparing the proposed pricing against other GSA resellers or the open market) and I'm not aware of any that have ever done so.

The memo states that the distributor/dealer is responsible for supporting all costs contained within its proposal.  Ingram is never the offeror/schedule holder of any GSA modification and/or proposal and therefore is not responsible for providing their costs, as the dealer provides their costs, as they are the offeror.

I do agree with the DoD memo when it states that any dealer who does not comply with the requirement to submit cost information for a contract or subcontract is ineligible for award.

 

So bottom line, I'm not certain what or to whom the DoD memo was directed at as it causes more confusion than clarity. 

Excellent GSA Sales History Tool

Not really a blog item but every GSA schedule holder should check out their reported GSA sales (and their competitors as well) by visiting this excellent web site - http://www.ffata.org/ffata/ (type in your GSA schedule # with no dashes)