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Citing the expense of updating its information systems, GSA is proposing to ask suppliers to report to GSA the information of what was acquired through GSA. This is like asking sellers offering through Amazon to report to Amazon what it offered, through Amazon. GSA SER. To take this example one action further, Amazon would then utilize that details to promote pricing to other customers, on Amazon.

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While not a perfect contrast, GSA in lots of methods operates as an Amazon-like part of the acquisition process. GSA Search Engine Ranker. The intent behind this guideline is seeking to make a best-in-class contracting market. Yet, GSA has chosen to hand down investing in an information collection system that could gather this information automatically.

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II (GSA SER Software). The Rule Imposes a Substantial, Underestimated, and Unnecessary Concern GSA estimates that it will take 6 hours for a specialist to achieve all tasks needed to comprehend the reporting requirements, prepare its systems and workers, and develop the procedures needed for developing the required reports, and an average 31 minutes each month for continuous reporting. Asia Virtual Solutions. 2 GSA does not offer adequate information to evaluate how these price quotes are flawed, however virtually every informed party who has actually weighed in on these estimates thinks they are inaccurate.

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Reg. 11625. The Small Company Administration's Office of Advocacy reports that small companies and their representatives are worried that GSA "under estimates the problem and resources." 3 The Council of Defense and Space Market Associations views the estimates as "grossly underestimated,"as stopping working to "account for costly modifications to info systems that will be needed to properly and entirely catch the information components required by the rule"or to "adequately account for the time needed to carry out quality assurance on draft submissions and examination into possible information anomalies that often emerge with transactional data reporting." 4 Based upon its experience with pre-award audits of contractor systems, the GSA Workplace of Inspector General "question [s] whether GSA's price quote of 6 hours per specialist to configure their systems for reporting is precise"and "contend [s] the projected burden of regular monthly reporting as 0.

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Otherwise, the professional will run the risk of an accusation of scams under the False Claims Act, as has actually been the case with basically every other type of price or expense reports sent by a professional to the federal government. Significantly for this hearing, small companies will bear the largest part of this concern-- GSA estimated that out of 15,738 suppliers holding agreements that would go through this Rule, 12,590 are small organizations. GSA Search Engine Ranker.

Reg. 11625. III. The Anticipated Advantage is Inadequately Defined, and Not --------------------------------------------------------------------------- Likely to be Realized GSA anticipates that the transactional data will "improve GSA's ability to perform significant price analysis and more efficiently and efficiently validate fair and affordable rates"on its agreements and will permit federal government buyers "to compare costs prior to putting orders." 8 GSA also acknowledges a point extremely important to industry-- that rate paid is just of lots of "info points"in figuring out the best value to the federal government. 9 Equally important are other factors to consider, "such as overall expense, desired performance levels, delivery schedule, special terms, time considerations, and client complete satisfaction." 10 We can likewise include customer care, product assistance services, guarantee, and other terms to this list.

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According to GSA's own analysis, this burden enforced on specialists will provide the federal government with just one of the necessary information points-- transactional rate-- without any methods to get the other details points required to evaluate cost (GSA SER Software). Without access to, and factor to consider of, this other important information, the rate information is of little worth at finest and can be extremely misleading at worst.

In my view, the inability of the Guideline to capture these other non-price elements could be specifically hazardous to small companies. Small companies often operate as value-added resellers or otherwise distinguish themselves in the competitive market based on the worth they contribute to a transaction, such as client and item service ability, that is not recorded by deal price.



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