GSA’s Acquisition Services Fund (ASF) is a revolving fund in the Treasury authorized by statute (40 U.S.C. 321) to support Federal Acquisition Service (FAS) operations. The ASF is essentially the result of the merger of the General Supply Fund (GSF) and the Information Technology Fund (ITF) that supported operations of the Federal Supply Service (FSS) and the Federal Technology Service (FTS). As part of the merger of FSS and FTS, the ASF fund was created to replace the GSF and the ITF.

The ASF receives no direct appropriations from Congress. The GSA Administrator is charged with determining the ASF’s cost and capital requirements for each fiscal year and developing a plan addressing those requirements in consultation with GSA’s Chief Financial Officer. Any change to the plan’s ASF cost and capital requirements for a fiscal year must be approved by the administrator.

The statute provides that, as part of the cost and capital plan, the administrator shall establish rates to be charged agencies that are provided for personal property and non-personal services through the ASF. Examples of rates charged agencies include the MAS program’s Industrial Funding Fee (IFF), the contract access fee included on the IT GWACs and OASIS, and the fees charged agencies for FAS’s assisted services support. In addition, the ASF is authorized to collect revenue from the net proceeds of personal property disposal and the receipts from carriers for loss of, or damage to personal property.

As mentioned above, the ASF supports direct procurement operations across FAS, including, but not limited to, Assisted Acquisition Services, General Supplies and Services, Integrated Technology Services and Travel, Motor Vehicle and Card Services. The ASF can also pay for the following: other direct costs of and indirect costs that are reasonably related to, contracting, procurement, inspection, storage, management, distribution, and accountability of property and nonpersonal services provided by the General Services Administration or by special order through the Administration. See 40 U.S.C. 321(c)(1)(C).

It appears that GSA uses this statutory authority to fund the Integrated Award Environment (IAE), the Common Acquisition Platform (CAP), and 18F.

The statute provides that, at the end of each fiscal year, the uncommitted balance of funds remaining in ASF, after making provisions for anticipated needs Federal agencies, shall be transferred to the general fund of the Treasury as miscellaneous receipts. A commitment occurs when the CFO concurs with a purchase request and fences the funds to support the pending requirement. An obligation occurs when the contract is signed or some mandatory action like payroll occurs. As part of the overall ASF plan, GSA may also maintain reserves to account for future needs, obligations, and investments.

Based on a review of publicly available documents, at the end of the last two fiscal years, the unobligated ASF balances appear to be approximately $2 billion at the end of FY 14 and $1.8 billion at the end of FY15. The unobligated balance, or “surplus”, affords FAS a significant tool to invest in the future. Two immediate opportunities for investment in the procurement system that would have immediate impact are:

1. Increasing investments in the development of the acquisition workforce.

2. Investing in internal systems to aggregate and report transactional data across the Federal enterprise.

First, increasing training and professional development for the FAS acquisition workforce manifests a commitment to the agency’s most important resource, its people, which will be reflected in continuous improvement of the efficiency and effectiveness of the MAS program. For example, MAS contractors currently report a lack of consistency in the application and/or understanding of the underlying pricing policies and procedures governing the negotiation and award of MAS contracts.

These inconsistencies can unnecessarily increase costs, delays, and uncertainty around contract awards and modifications. Training can help address this concern! Make no mistake, the Coalition understands the importance FAS management places on supporting the acquisition workforce, which is why it supports providing FAS management with more resources to increase opportunities for training and professional development. Again, it is an investment in the future of FAS.

Second, consistent with ASF’s ability to fund other direct and indirect costs associated with procurement operations a portion of the unobligated balance or reserve should be set aside to fund/support the development of internal systems for the aggregation and reporting of transactional data across the federal enterprise.

This should be done in lieu of imposing costly transactional data reporting requirements on MAS contractors. As they stand now, the proposed transactional data reporting requirements amount to a “tax” on MAS contractors and agency users. Indeed, the Coalition, in its comments on the proposed transactional data rule, specifically noted that the costs associated with the implementation and ongoing management of the rule are in the hundreds of millions of dollars annually. These costs eventually will be passed on to government customers through higher contract prices.

Rather than imposing a costly new reporting system on government contractors, and ultimately, agency customers, FAS should use the ASF to fund a pilot for an internal transactional data reporting system that would allow GSA to collect and share transactional data from customer agencies. By piloting such a system, GSA could assure that it has the processes in place to secure proprietary and/or FOIA-protected vendor information.

It should be remembered that, under the rule, GSA is asking contractors to report data the government already has in its possession. This investment merely represents a less costly and more efficient alternative for GSA to access the data it possesses than the proposed rule. Clearly, the precedent for such an approach already exists, as one need only to look to IAE, CAP, and 18F

This commentary was originally published on Roger Waldron’s website, The Coalition for Government Procurement, and was republished here with permission from the author.

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