Gsa finalizes major update to acquisition policy

The Commercial Sales Practices regulation requires contractors to disclose to GSA details of any discounts vendors offer to commercial customers for similar products and services. Youtube electricity The Price Reduction Clause requires contractors to monitor their pricing over the life of the contract and provide the government with the same price reductions that they give to commercial customers.

The PRC has been at the center of most of government contracting-based False Claims Act whistleblower cases and settlements over the past decade. Gas vs diesel generator For much of the past decade, vendors have called on GSA to change the PRC because it doesn’t match up with how agencies buy or how contractors sell anymore.

“Accordingly, the rule provides for a measured and managed phase-out of disclosures and tracking currently required by the Commercial Sales Practices (CSP) format and the Price Reductions clause (PRC), and the associated practice of negotiating pricing based on a model where the government strives to secure the vendor’s most favored pricing and maintain this position for the life of the contract,” the final rule stated. Wd gaster battle “Instead, GSA is adopting a more dynamic market driven pricing model, where vendors submit prices paid by government customers through a new Transactional Data Reporting clause and the government uses this data, along with other pricing information, to ensure a vendor’s offered price is competitive relative to other vendors selling the same or similar items or services.” GSA listened to industry

Roger Waldron, the president of the Coalition for Government Procurement and a former member of the Acquisition Advisory Panel, said the removal of the CSP requirement is a huge change for vendors.

“Changing or eliminating the CSP disclosure requirement is a good example where GSA listened to feedback they got from public about that aspect of the proposed rule,” Waldron said. Gasbuddy touch “In the proposed rule, GSA maintained the CSP and stated that they could ask for updates at any time for CSP, which essentially made that akin to potential liability under PRC and could’ve even expanded the compliance burden. Gas 1940 So that’s why this is a positive change.”

Waldron, like many associations, still was digesting the 185-page final rule. National gas average 2007 The Coalition was one of more than two dozen commenters on the proposed rule.

A GSA spokesperson said GSA held the first public meeting on an agency acquisition regulation in 20 years in spring 2015, and heard from nearly 200 companies, organizations, government agencies and interest groups GSA also received 26 comment letters in response to the proposed rule and held two rounds of public comment before issuing the final rule.

GSA also said it relooked at how it calculated the burden of the proposed rule and refined its methodology. The agency said with the changes to the PRC and CSP, contractors should see a net reduction of burden of $29 million. Electricity videos for students But contractors on GWACs could see an increased burden of $3 million.

Trey Hodgkins, the senior vice president for the IT Alliance for Public Sector, said looking at GSA’s revised burden estimates still leaves too many questions. Gas 87 89 93 Trey Hodgkins, senior vice president for the public sector at IT Alliance for Public Sector

“GSA is making presumptions about how easy it is to collect the data. Gas prices I’m not sure our member companies agree with that,” he said. Mp electricity bill payment online bhopal “It shifts burden, but I’m not sure if lessens the burden.”

“They do not account for lower-sales contractors and efficiencies achieved through automation,” the spokesperson said. Npower electricity bill “In contrast, GSA’s projections acknowledge vendors with higher contract revenue will be more likely to adopt automated reporting systems, which will require large upfront investments. Gsa 2016 new orleans In return, automation will allow those vendors to minimize the recurring monthly reporting burden. Electricity outage chicago Some vendors with a moderate amount of sales may not make large upfront investments in automation, and will instead opt to absorb a higher recurring monthly reporting burden. Bp gas station Vendors with low/no sales will not make upfront investments in automation because their reporting burden will be low regardless.”

GSA also said the higher burden estimates still pale in comparison to the current burdens imposed by the PRC and CSP disclosure requirements, which industry frequently acknowledges as burdensome.

Alan Chvotkin, the senior vice president and counsel for the Professional Services Council, said while his members are glad to see the change in the CSP, there is plenty in the rule that worries him.

“While there is a phase out of the PRC and change in the CSP, they still exist and the agency’s inspector general in their last report still raises concerns that this rule gives away too much. Electricity and magnetism worksheets 8th grade I think we still have a disagreement about the continued value of PRC and how much is changing,” Chvotkin said. Electrical supply company near me “Our concern is that the PRC is only for the schedules program and this will apply beyond the schedules, and the PRC will still matter during its phase out for some time. E payment electricity bill maharashtra I’m worried about the effectiveness of this policy.”

Larry Allen, the president of Allen Federal Business Partners and an expert on schedule contracts, said while GSA’s intent is good to remove the CSP, it’s unclear as to whether it’s a permanent change.

“GSA still leaves the door open, however, to collect commercial pricing information from contractors if price reasonableness cannot be determined by preferred methods such as similar pricing on schedule, transactional database prices, market research, or commercial data sources,” he said. Gas variables pogil worksheet answer key “My concern is that a generation of contracting officers used to getting CSP data will run right to what is intended to be the method of last resort and make it the method they use because it is what they are used to seeing and less burdensome on them because they don’t have to do data collection and pricing analysis from other sources. Gas pump heaven My hope is that GSA trains contracting officers not to do this, but only time will tell.” Rule implemented in a series of pilots

In fact, several industry experts said the final rule is murky in some major areas, including the PRC, how GSA will ensure contracting officers use the data to make good decisions and why the government needs to collect this data in the first place.

“This is data the government already possess or should easily be able to capture, and they should not make the contractor incur the extra burden,” Hodgkins said. Q gas station “I don’t agree with the fact that they are asking for the data in the first place. F gas regulations 2015 This is really a technical issue. Gas house pike frederick md They have the systems and are aware of the information, but the systems are not configured to capture the data. Electricity nightcore lyrics We do not object to the end use of the data as it makes sense to try and find best value for taxpayer. Gas tax in new jersey But these are technical changes they could make.”

Allen added that he’s also concerned that the database that is supposed to collect all this transactions data will be unworkable in terms of drawing accurate comparisons.

“Industry has tried to make clear that pricing decisions are made by an almost infinite number of variables. Electricity quiz ks3 I think there’s a tendency to look at Schedule transactions as if they all took place in a Home Depot environment where actual products are picked off the shelf at identified prices,” he said. Gas prices going up or down “For the vast majority of schedule transactions, though, a more accurate comparison would be the Dow Jones Industrial Average where prices go up and down both during the day, the week, month, and year depending on many factors. Electricity and magnetism notes As such, I am not sure that the information on the database will become a major factor in helping agencies get lower prices. Gaz 67 dakar In fact, I think it could have the opposite effect. Gas and water Now industry knows that each and every deep discount will become viewable on a database accessible by all federal agencies. Electricity worksheets grade 6 As a result, I expect contractors to be more careful about when they offer discounts and how deep those discounts are. Gas mask ark Spot pricing, which has been allowed on the Schedules program for 25 years, has worked well in that ‘spot’ prices are just that — good discounts available to a specific customer. Gas monkey monster truck body Expect to see far fewer deep discounts on Schedule if ‘spot’ no longer means ‘spot,’ but rather a price to which every customer is entitled.”

GSA plans on implementing the rule over the next year in a series of pilots beginning in August. Electricity lessons grade 6 The spokesperson said the final rule will be phased in over a three-year period.

“GSA has established clear policy, effective training, and user-friendly tools to ensure successful implementation. Impact of electricity in the 1920s In addition, GSA will conduct change management and knowledge-sharing activities with category managers, GSA COs, and federal buyers to fully harness the power of the transactional data collected through the pilot,” the spokesperson said. Gasket t 1995 “Training will be provided via live webinars. Electricity synonyms Webinar recordings will be available for on-demand viewing from the Vendor Support Center website. Gastronomia y cia Initially, any new offer on the pilot Schedules will be required to agree to the TDR requirement. Electricity and magnetism worksheets 4th grade GSA will invite existing contractors to accept the TDR requirement, which removes the CSP and PRC requirements. Electricity billy elliot karaoke with lyrics GSA may require existing contractors to accept the TDR requirement over time.”

“I would’ve preferred they issue this as rule only covering the pilot activities and really test it out,” he said. Gas 66 “We are not pleased that professional services are a part of the pilot. Gas leak chicago It’s harder to do this transaction reporting around services, which is just what we argued during acquisition panel. Arkla gas pay bill It would be easier to phase in the changes on commodities.”