The Federal procurement world is perceived in the industry as constantly shifting, endlessly tinkered with, and restlessly unstable.  It is a fairly common pattern for a top-down initiative or policy change to be broadcast by the Government, only to be met by a hostile chorus of hardened, reactionary contractors prepared to list every reason why any given change is a bad one.  The best way to remedy this troubling pattern is to provide feedback before an impactful announcement or change is made.  Sometimes, it appears that opportunity for feedback prior to a change is inadequate.  However, even when the opportunity is granted, studies show that most contractors still do not seize it.  The present day offers two such high-profile efforts at preliminary transparency.

GSA’s Class Deviation RFI

As of March 20, 2015, GSA has released a RFI that strongly encourages contractor feedback.  It is in the best interest of many contractors to read it carefully and respond to GSA by the due date of April 20, 2015.  The somewhat verbose Notice is entitled “Notice of a Class Deviation To Address Commercial Supplier Agreement Terms Inconsistent With Federal Law”.

The impetus for creation of this RFI is the frequent interference that Commercial Supplier Agreements run into when clashing with incompatible Federal law.  These discrepancies are larger and growing larger as Commercial Supplier Agreements spread from technology acquisition to various other areas. The general idea is to minimize time and resource-consuming negotiation by setting a clear order of precedence, deviating from FAR regulations and giving greater considerations to commercial interest.  This has the potential to benefit contractors, so an opportunity to endorse or otherwise comment on this initiative should not be passed up.

OFPP’s Acquisition 360 Initiative

The Office of Federal Procurement Policy, headed by Anne Rung, has shown an unrelated but equally large-scale request for contractor feedback through the Acquisition 360 initiative.  360 refers to the circular nature of the program, in which the contracting office and program office rate each other.   One potential drawback has been identified: this is a survey-oriented approach, which places it at risk for being overlooked or glossed over by a public that has grown weary of the sheer number of surveys pitched at it.  Other than this limitation, the survey questions appear to have been crafted from a perspective of an organization seeking measurable gains.  Whether the initiative succeeds or fails hinges largely on how actionable this feedback actually turns out to be.  This remains to be seen, and will go a long way in determining the overall benefits of Acquisition 360.

Conclusion

Whether one of these feedback initiatives affects you; or both do; or neither does but you still have an opinion; it is encouraged that contractors get in the habit of seizing these opportunities to make their voices heard.   With greater feedback comes more attention from the Government and hopefully, more opportunities for feedback.  Eventually, the goal is to turn the federal Government procurement marketplace into an increasingly transparent entity, ultimately reducing the size and scale of the bastion of naysayers that comes forward to denounce each upcoming Government initiative as foolish and unilateral.  March 2015 is as good as any place to start.

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