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Challenges and Solutions in Federal Procurement: Addressing Pricing Policy and Data Overreach in the MAS Program
Government Procurement Policy Overreach Threatens Small Businesses and Innovation
In a recent development, the Biden Administration’s focus on leveraging the procurement system to meet small business procurement goals and address key social policy priorities is being hindered by pricing policy and data overreach within the General Services Administration’s (GSA) Multiple Award Schedule Program (MAS).
Pricing Policy Overreach
The implementation of FAS Policy and Procedure (PAP) 2021-05, Evaluation of FSS Program Pricing, has led to conflicting rules and burdensome submission/evaluation requirements for potential contractors. This policy directive has particularly impacted Economic Price Adjustment (EPA) and product/service addition modifications transactions, causing delays and increased costs for contractors, especially small businesses. The requirement to renegotiate entire contracts when proposing modifications hinders small business opportunities and limits access to sustainable products, cybersecurity capabilities, and innovation from the commercial market.
The Coalition has provided feedback on the PAP to FAS and is advocating for a dialogue to address the overreach. By rectifying this issue, FAS can better support customer agency missions and further the Administration’s goals for small businesses, sustainability, cybersecurity, supply chain reliance, and innovation.
Data Overreach
In addition to pricing policy overreach, the current MAS solicitation includes templates and practices that are inconsistent with commercial practice, creating significant administrative burdens for contractors. The requirement to submit each possible configuration of configurable products into pricing templates is burdensome and costly, especially for industries with numerous configurations like furniture and information technology. This disconnect between MAS market practices and commercial practices reduces opportunities for small businesses and access to innovative products.
To address these challenges, FAS should consider a more “performance-based” approach to data submission rather than the current prescriptive framework. Utilizing reverse industry days and engaging with industry partners can enhance understanding of the commercial market and improve pricing policy approaches. By rethinking the PAP and solicitation data submission requirements, FAS can better promote policy imperatives and meet mission needs.
Overall, the overreach in pricing policy and data submission within the MAS program threatens small businesses and innovation. Collaborative efforts between stakeholders, including the Coalition, are essential to rectifying these issues and ensuring the efficient and economic acquisition of goods and services in line with key social policy priorities.
