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Published Oct 08, 21
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HORAN. GSA SER Software. 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, thinking about the expense to the contractors. I do not think they can do that based on the way in which the proposed guideline is executed here.

Small businesses are known for the included value they can supply agencies with advantages such as client service - GSA SER Services. Mr. GSA SER Software. Horan, you stated in your testimony that the new guideline does not account for such added worth. Again, that it might be-- the procurement could be driven to low cost only, and as a result of that, the specialists who use some of these other terms and services that supply best value will lose sales at a minimum, possibly be driven out of the market.

Because they are out of the company or they are simply not bidding anymore? Because they are out of the organization. Due to the fact that there is such pressure on contracting officers to look at only low cost that in some cases they will exclude factor to consider of best value however ultimately, I think they could be out of the service.

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TAKAI. Okay, thank you (GSA SER Software). The quotient for government procurement study in its study, small companies show that it would handle average 232 hours to comply with the GSA's proposed guideline. Mr. Stanford, has your business done its own quote on the hours it will require to abide by the new requirement, and do you find the results of the survey to be more accurate than GSA's own analysis? Mr.

We have not. And while we have actually taken a look at their research study and the ABA work, we are also encouraged in accepting their conclusion because also SBA Workplace of Advocacy and GSA's own inspector general determined that those expenses seem understated. Mr. TAKAI. Their, meaning the union, not GSA's? Mr. STANFORD.

Mr. TAKAI. Okay. Other than our spin on compliance, can you discuss some other costs that companies like yours will have to face because of this rule? Mr. STANFORD. I will not speak to our business separately, but speaking with the business we work with as they enter the federal market, the expenses beyond compliance are-- for small companies are preliminary expenses up front.

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Pointing out the expense of upgrading its information systems, GSA is proposing to ask vendors to report to GSA the information of what was acquired through GSA. This resembles asking retailers offering through Amazon to report to Amazon what it offered, through Amazon. To take this example one step even more, Amazon would then use that information to market pricing 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 process. The intent behind this rule is seeking to make a best-in-class contracting market. GSA has decided to pass on investing in an information collection system that might gather this information automatically.



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II. The Rule Enforces a Substantial, Underestimated, and Unnecessary Concern GSA estimates that it will take six hours for a professional to achieve all tasks needed to comprehend the reporting requirements, prepare its systems and personnel, and develop the procedures required for developing the needed reports, and an average 31 minutes monthly for continuous reporting. 2 GSA does not offer sufficient information to examine how these price quotes are flawed, but practically every notified celebration who has actually weighed in on these estimates thinks they are unreliable.

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Reg. 11625.

Otherwise, the specialist will run the risk of a claims of scams under the False Claims Act, as has held true with basically every other form of rate or expense reports sent by a specialist to the government. Significantly for this hearing, small businesses will bear the biggest part of this burden-- GSA approximated that out of 15,738 vendors holding agreements that would be subject to this Guideline, 12,590 are small businesses (GSA Search Engine Ranker Services).

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Reg. 11625. III. The Anticipated Benefit is Improperly Defined, and Not --------------------------------------------------------------------------- Likely to be Understood GSA anticipates that the transactional data will "improve GSA's capability to carry out meaningful rate analysis and more efficiently and effectively validate fair and affordable rates"on its agreements and will permit federal government purchasers "to compare rates prior to positioning orders." 8 GSA also acknowledges a point extremely crucial to market-- that cost paid is only of many "info points"in identifying the very best worth to the government. 9 Similarly essential are other considerations, "such as total expense, wanted performance levels, delivery schedule, distinct terms and conditions, time considerations, and client satisfaction." 10 We can also add customer service, item assistance services, warranty, and other terms to this list (GSA Search Engine Ranker Software).

So, according to GSA's own analysis, this problem troubled professionals will supply the government with just one of the required details points-- transactional price-- with no methods to get the other information points required to examine price. Without access to, and consideration of, this other crucial information, the price details is of little value at best and can be extremely misleading at worst.

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In my view, the failure of the Guideline to capture these other non-price elements might be especially hazardous to small companies. Small companies typically operate as value-added resellers or otherwise distinguish themselves in the competitive market based on the value they add to a deal, such as customer and product service ability, that is not captured by transaction price.

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