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HORAN. GSA Search Engine Ranker Services. Well, the method I would like then to figure it out is if it in fact produces a better value, best value to the government, considering the cost to the specialists. I do not think they can do that based on the manner in which the proposed rule is executed here.

Small companies are known for the included value they can provide firms with advantages such as consumer service. Big corporations or huge companies can not do that. Mr. Horan, you mentioned in your statement that the new guideline does not account for such added value. GSA SER Software. What could this omission imply not just to small vendors but also to the firms that acquire their goods and services? Mr.

I think those other terms that result in best worth might be lost. Again, that it could be-- the procurement could be driven to low rate only, and as a result of that, the specialists who offer some of these other terms and services that offer best value will lose sales at a minimum, perhaps be eliminated of the market.

Mr. TAKAI. Because they run out the organization or they are just not bidding anymore? Mr. HORAN. Because they are out of the organization. I suggest, there are other problems as well. Since there is such pressure on contracting officers to take a look at just low cost that sometimes they will leave out factor to consider of best value but eventually, I believe they could be out of the company.

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TAKAI. Okay, thank you (GSA Search Engine Ranker Software). The ratio for government procurement study in its study, small companies indicate that it would take on typical 232 hours to abide by the GSA's proposed rule. Mr. Stanford, has your service done its own price quote on the hours it will take to abide by the new requirement, and do you find the outcomes of the survey to be more precise than GSA's own analysis? Mr.

We have not. And while we have actually looked at their research study and the ABA work, we are likewise motivated in accepting their conclusion since likewise SBA Workplace of Advocacy and GSA's own inspector general identified that those costs seem downplayed. Mr. TAKAI. Their, indicating the coalition, not GSA's? Mr. STANFORD.

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

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Pointing out the cost of upgrading its information systems, GSA is proposing to ask vendors to report to GSA the details of what was purchased through GSA. This resembles asking merchants selling through Amazon to report to Amazon what it sold, through Amazon. To take this example one step even more, Amazon would then utilize that information to advertise rates to other customers, on Amazon.

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While not an ideal comparison, GSA in lots of methods operates as an Amazon-like part of the acquisition procedure. The intent behind this rule is seeking to make a best-in-class contracting market. Yet, GSA has actually chosen to hand down purchasing an information collection system that might gather this info automatically.

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II. The Rule Imposes a Significant, Underestimated, and Unnecessary Burden GSA approximates that it will take six hours for a specialist to achieve all jobs required to understand the reporting requirements, prepare its systems and workers, and develop the procedures needed for creating the needed reports, and a typical 31 minutes monthly for continuous reporting. 2 GSA does not offer adequate detail to analyze how these price quotes are flawed, but virtually every informed party who has actually weighed in on these quotes thinks they are inaccurate.

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Reg. 11625.

Otherwise, the professional will run the risk of a claims of scams under the False Claims Act, as has actually been the case with essentially every other form of rate or expense reports submitted by a professional to the government. Notably for this hearing, small companies will bear the largest part of this concern-- GSA estimated that out of 15,738 vendors holding agreements that would be subject to this Rule, 12,590 are small companies (GSA Search Engine Ranker).

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Reg. 8 GSA also acknowledges a point really essential to market-- that cost paid is just of many "information points"in identifying the best value to the government. 10 We can also include client service, product assistance services, warranty, and other terms to this list.

According to GSA's own analysis, this problem imposed on specialists will supply the government with only one of the essential details points-- transactional price-- without any methods to acquire the other info points essential to assess cost. Without access to, and factor to consider of, this other crucial details, the cost information is of little worth at finest and can be really misleading at worst.

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In my view, the failure of the Guideline to capture these other non-price aspects could be specifically damaging to little organizations. Small businesses frequently operate as value-added resellers or otherwise distinguish themselves in the competitive market based upon the worth they contribute to a transaction, such as client and product service ability, that is not captured by transaction rate.



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