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I hope the GSA will either desert this technique and start over or seriously remodel the rule prior to it becomes final. This is a concern the Subcommittee will be keeping track of and will continue to keep an eye on, and we eagerly anticipate having another chance to meet you if that is very important.

Without objection, so ordered. And thank you again. 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. The issues with the Proposed Guideline are numerous. The 4 that I am going to discuss today are especially pertinent to small organizations. GSA grossly underestimates both application costs and compliance costs of transactional data reporting.

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Third, it does not appear that GSA is certain how it will use the large quantity of data that it looks for to collect under the Proposed Rule, however the potential for downward rates pressure that likely will result from transactional information reporting might have a disproportionate impact on small services who rarely win a "race to the bottom" on prices.

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This data also is secured from disclosure under the Trade Tricks Act. Select Congress Relating To the Proposed Transactional Data Guideline A. Estimated Implementation and Reporting Expenses of the Transactional Data Rule GSA approximates that the public reporting concern for its contractors to initially set up systems for transactional information reporting at 6 hours. 3 GSA estimates that the month-to-month concern afterwards will average 4 around 0.

e - GSA Search Engine Ranker Software. sales) and presumes monthly reporting burden increases with supplier sales based on the distribution of sales and commitments within FSS contracts and non-FSS agreements." 6 What GSA allows no time for is system improvements that might be required should GSA elect to alter the fields of data to be reported as it would can do upon 60 days notice under the Proposed Guideline. 7 In addition, these estimates of six hours for preliminary set-up and 31 minutes monthly for ongoing reporting are grossly underestimated.

9 This estimate likewise includes the effort that GSA prepares for professionals will be required to make to institute modifications to specialist training, compliance systems, settlements, and audit preparation-- and probably consists of the time and cost needed to modify information- event, reporting, and information-technology (IT) systems to accurately and efficiently report the data required by the Proposed Rule. 10 GSA's own Inspector General's workplace acknowledges that specialists likely will invest far more than 6 hours to set up organization systems for transactional information reporting. 11 As the GSA Workplace of Inspector General notes in its remarks to the Proposed Guideline: --------------------------------------------------------------------------- 8 Id.

Given this, we question whether GSA's estimate of 6 hours per specialist to configure their --------------------------------------------------------------------------- systems for reporting is accurate - GSA SER. 12 12 Id. This six hour quote should assume that all information fields reside in the very same IT system and that the report can be set up by one person without consultation with others inside or outside the business.

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In most cases, the systems that house the different fields GSA is requesting in its month-to-month report are not set approximately interact with one another. Appropriately, some contractors will require to by hand assemble the details needed for transactional data reporting, or may need to update their IT systems in --------------------------------------------------------------------------- order to comply (GSA Search Engine Ranker).

For some specialists, particularly small companies, setting up systems to catch and report transactional information may involve assessment with specialists outside the business at hourly rates therefore increasing the costs to the contractor. These estimated costs are not factored into GSA's six hour estimate for established. 13 --------------------------------------------------------------------------- 13 As kept in mind in the ABA's Comments to the Transactional Data Rule: The Section recommends that the hours required will in truth be much higher.

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Many specialists might need substantial modifications or upgrades to service systems in order to supply the data sought by GSA in a kind that will allow for meaningful and accurate pricing comparison as meant. For example, the fields required by GSA for transactional-data reporting might not live in the same IT system; few accounting systems consist of both manufacturer part number and professional part number in the same system when those part numbers vary.

g., products management) to meet the requirements of the Proposed Rule. These and other required changes would need coordination amongst functions such as the contractors' IT departments and change management teams in addition to accountable executives. The time required just to search for, extract, evaluation, and test such information, and execute system adjustments, will well surpass 6 hours.

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Moreover, the estimated 31 minutes each month does not consist of any time enabled for continuous upkeep of information, consisting of however not restricted to modifications by GSA to the data fields required as permitted by the Proposed Guideline. 14 Given the unidentified implications on a specialist need to it supply data to GSA that is unreliable or incomplete, specialists will require to review the transactional data prior to submission which could take hours depending upon the size of the agreement.

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--------------------------------------------------------------------------- 14 80 Fed. Reg. 11628. B. GSA's Proposed Expansion of Industrial Sales --------------------------------------------------------------------------- Practice Disclosure Requirements is Unduly Troublesome All GSA contractors must prepare and submit CSPs prior to award and at certain key times during efficiency of a GSA contract. When a professional looks for to increase costs or add products to the agreement GSA needs either new CSPs, or a declaration from the professional that the CSPs have not changed because the time they were last submitted.

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Due to the possible financial risks produced by incorrect CSP disclosures, specialists should invest significant time evaluating sales data and preparing existing, accurate and total CSPs when they are required to do so (Asia Virtual Solutions). Even a statement that the CSPs have not changed requires extensive review of transactional sales information to validate that this declaration is correct at the time that it is made.

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