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Federal Acquisition Regulation: Strategic Sourcing Documentation

July 20th, the GSA, NASA, and DOD submitted a proposed rule to the federal register and opened the discussion to the public. The rule would add the National Defense Authorization Act for Fiscal Year 2015 (NDAA) language to the FAR 8 making it a requirement of all GSA Schedule purchases.

The NDAA states that if a Government buyer purchases a product that is available on FSSI, but doesn’t use FSSI, then the buyer must complete an analysis of the comparative value, including price and non-price factors, between the supplies and services offered under the FSSI and those offered under the source(s) being used for the purchase.

This change will make not using the FSSI vehicle more administratively burdensome causing Government buyers to use FSSI even if a lower priced item or value added service is available elsewhere, just to avoid the extra administrative work.

GSA has championed the FSSI since inception and have claimed increased spending to small business, albeit only 78 small businesses.  The rule would effectively ensure FSSI’s success as a preferred vehicle by forcing burdensome administrative analysis to justify not using it.

The Initial Regulatory Flexibility Analysis (IRFA) found that the new rule may have a negative impact on businesses not on FSSI because “…the required contracting officer consideration and documentation requirement could indirectly lead to more purchases going to those vendors involved in the FSSI”

FSSI contracts are reopened and competed briefly every two years, so this is great news if you are one of the 137 vendors awarded to any one of the 7 FSSI programs; but potentially detrimental to the 24,000 schedule holders not on FSSI.

Clever vendors and eager buyers will find a way to connect without the FSSI. One way to help buyers buy from you if you’re not on FSSI is to offer value-added services (non-price factor) and/or lower prices than those on FSSI for the same products. Doing so will help buyers justify buying from you.

We continually monitor FSSI announcements and openings and will keep our clients informed of all changes and new opportunities.

If you would like to provide your thoughts to the proposed rule go to https://www.regulations.gov/docket?D=FAR-2015-0015 and have your opinion heard.

 

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