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I hope the GSA will either abandon this approach and start over or seriously rework the rule before it ends up being final. This is a concern the Subcommittee will be monitoring and will continue to monitor, and we look forward to having another opportunity to consult with you if that is very important.

Without objection, so ordered. This hearing is now adjourned. And thank you once again. [Whereupon, at 11:33 a. m., the Subcommittee was adjourned.] A P P E N D I X [GRAPHICS NOT READILY AVAILABLE IN TIFF FORMAT] 1. Introduction 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. GSA grossly ignores both implementation costs and compliance costs of transactional information reporting.

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Third, it does not appear that GSA is specific how it will utilize the voluminous quantity of data that it seeks to collect under the Proposed Guideline, however the capacity for down pricing pressure that likely will arise from transactional information reporting may have a disproportionate impact on small companies who hardly ever win a "race to the bottom" on rates.

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

e - GSA Search Engine Ranker. sales) and assumes month-to-month reporting burden increases with vendor sales based on the distribution of sales and obligations within FSS agreements and non-FSS agreements." 6 What GSA permits no time for is system enhancements that might be needed needs to GSA choose to alter the fields of data to be reported as it would can do upon 60 days notification under the Proposed Guideline. 7 In addition, these quotes of 6 hours for initial set-up and 31 minutes monthly for ongoing reporting are grossly underestimated.

Reg. 11625. 3 Id. 4 GSA approximates a variety of two minutes (for professionals with $0 in sales) and four hours (for specialists with higher than $50 million in sales). See id. 5 Id. 6 Id. 7 Id. at 11628. 1. Preliminary Set-Up Likely Will Far Exceed 6 --------------------------------------------------------------------------- Hours GSA estimates that its contractors will spend around six hours to set up its systems to generate the monthly report needed by the Transactional Data Rule. 8 This six-hour estimate consists of the time that GSA price quotes will be required for reviewing instructions, browsing existing databases and other sources of information, and gathering and evaluating the collected details. 9 This quote also consists of the effort that GSA anticipates professionals will be required to make to set up changes to specialist training, compliance systems, settlements, and audit preparation-- and most likely consists of the time and cost needed to modify information- event, reporting, and information-technology (IT) systems to precisely and efficiently report the information needed by the Proposed Guideline. 10 GSA's own Inspector General's office acknowledges that specialists likely will invest much more than six hours to establish organization systems for transactional data reporting. 11 As the GSA Workplace of Inspector General notes in its comments to the Proposed Rule: --------------------------------------------------------------------------- 8 Id.

Offered this, we question whether GSA's estimate of 6 hours per contractor to configure their --------------------------------------------------------------------------- systems for reporting is precise - GSA Search Engine Ranker Software. 12 12 Id. This six hour price quote should presume that all data fields reside in the very same IT system and that the report can be established by one individual without consultation with others inside or outside the business.

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In numerous 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 professionals will need to manually compile the information required for transactional information reporting, or might require to upgrade their IT systems in --------------------------------------------------------------------------- order to comply (Asia Virtual Solutions).

For some professionals, particularly small services, establishing systems to catch and report transactional data may include assessment with professionals outside the business at hourly rates consequently increasing the costs to the specialist. These approximated costs are not factored into GSA's six hour estimate for established. 13 --------------------------------------------------------------------------- 13 As kept in mind in the ABA's Remarks to the Transactional Data Guideline: The Area suggests that the hours required will in fact be much greater.

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Lots of contractors might need substantial modifications or upgrades to service systems in order to offer the information sought by GSA in a form that will enable for significant and precise prices comparison as planned. For example, the fields required by GSA for transactional-data reporting may not live in the very same IT system; few accounting systems include both maker part number and contractor part number in the exact same system when those part numbers vary.

g., materials management) to satisfy the requirements of the Proposed Rule. These and other required modifications would require coordination amongst functions such as the contractors' IT departments and change management groups in addition to accountable executives. The time required just to search for, extract, evaluation, and test such information, and execute system adjustments, will well go beyond 6 hours.

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The estimated 31 minutes per month does not consist of any time enabled for continuous upkeep of data, including however not restricted to modifications by GSA to the data fields required as permitted by the Proposed Rule. 14 Provided the unidentified implications on a specialist ought to it supply data to GSA that is incorrect or insufficient, contractors will require to examine the transactional information prior to submission which could take hours relying on the size of the agreement.

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B. GSA's Proposed Expansion of Business Sales --------------------------------------------------------------------------- Practice Disclosure Requirements is Unduly Troublesome All GSA contractors need to prepare and submit CSPs prior to award and at particular key times throughout performance of a GSA contract. When a contractor looks for to increase rates or include products to the agreement GSA requires either brand-new CSPs, or a statement from the contractor that the CSPs have not changed given that the time they were last submitted.

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Due to the potential financial threats produced by incorrect CSP disclosures, professionals should invest substantial time examining sales data and preparing existing, accurate and complete CSPs when they are required to do so (GSA SER Services). Even a statement that the CSPs have actually not changed needs extensive evaluation of transactional sales information to validate that this declaration is correct at the time that it is made.



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