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Challenges and Solutions in Federal Procurement: Addressing Pricing Policy and Data Overreach in the MAS Program
The Biden Administration’s focus on leveraging the procurement system to meet small business procurement goals and address key social policy priorities has faced challenges due to pricing policy and data overreach within the GSA’s Multiple Award Schedule Program (MAS). The implementation of FAS Policy and Procedure (PAP) 2021-05 has led to conflicts with underlying regulations, imposing burdensome submission and evaluation requirements on potential contractors. This has particularly affected MAS small businesses, hindering opportunities for sustainable products, cybersecurity capabilities, and innovation.
The PAP’s impact on the program has driven the over-submission of documentation, increased costs for contractors, and delayed the addition of products to current contracts. The requirement for contractors to renegotiate their entire contract when proposing modifications to add new products or services has created uncertainty in the MAS market and discouraged contractors from adding innovative items to their contracts. Additionally, the current MAS solicitation includes templates and practices that are inconsistent with commercial practice, creating significant administrative burdens for contractors offering configurable products.
Efforts to address the overreach of pricing policy and data submission requirements are crucial to better support customer agency missions and Administration policy goals. Suggestions include clarifying the status of template data in the solicitation, adopting a more performance-based approach to data submission, and engaging in reverse industry days to enhance understanding of the commercial market. Collaboration between stakeholders, including Coalition members, is essential to overcoming these challenges and promoting policy imperatives while meeting mission needs.
