Creating contract duplication to reduce contract duplication?

This column was originally published on Roger Waldron’s blog at The Coalition for Government Procurement and was republished here with permission from the author.

On April 14, the Defense Information Systems Agency (DISA) issued Solicitation NO. HC1047-17-R-0007, a request for proposals (RFP) seeking to establish 12 multiple award IDIQ contracts for Agency Program Support (APS) services. The scope of DISA’s APS contracts will include:

• Acquisition and Contract Management Support
• Asset Management Support
• Continuity Management Support
• Directorate Security Support
• Financial Management Support
• Information Resources Support
• Program Management Support

The scope of all services being sought through this small business set-aside already are available to DISA through the IT GWACs, OASIS,and GSA Schedules. As DISA notes on page 9 of the solicitation:

“Prior to the Agency reorganization in 2015 and 2016, the Agency fulfilled these types of requirements using various stand-alone contracts, General Services Administration (GSA) schedules, Government-wide Acquisition Contracts (GWACs), and other Component contract vehicles. A strategic goal of the Agency reorganization was to consolidate and streamline acquisitions with relevant requirements.”

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As DISA itself notes, the IT GWACs, OASIS and GSA Schedules already exist to meet DISA’s immediate and ongoing program support needs through streamlined task order competitions. Moreover, the flexibilities of the GSA Schedule and IT GWACS allow for setting aside orders to achieve small business goals. In particular, the GSA Schedules are the single most successful government-wide contracting program and has significant small business participation.

Yet, industry (in this case small business) is again being asked to invest scarce bid and proposal, and administrative costs to compete for a full blown, new IDIQ contract when pre-existing contracts will meet the need. The department and its industry partners cannot afford to continue a parochial approach to contract creation. Parochial contract creation results in costly governmental contract duplication.

DISA’s decision to create a new contract vehicle for support services rather than utilizing pre-existing governmentwide contracts also appears fundamentally inconsistent with recent guidance from the Office of Management and Budget (OMB).

On April 12, OMB Director Mick Mulvaney issued a memorandum entitled “Comprehensive Plan for Reforming the Federal Government and Reducing the Civilian Workforce.” This memorandum provides guidance on agency reorganization and reform, as mandated by the President’s recent executive orders, along with an appropriate, necessary focus on improving organizational efficiency and effectiveness through streamlining processes, shared services and leveraging existing solutions.

Of particular note, the OMB memorandum directs the following:

“Agencies should consider government-wide contracts for common goods and services to save money, avoid wasteful and redundant contract actions, and free-up acquisition staff to accelerate procurements for high-priority mission work. To the maximum extent practicable, especially for the acquisition of common goods and services, agencies shall use existing contract solutions such as:

• “Federal Supply Schedules
• “Government-wide acquisition contracts
• “Multi-agency contracts; and
• “Any other procurement instruments intended for use by multiple agencies.”

The Coalition applauds OMB for tackling contract duplication and we look forward to working with all stakeholders to leverage shared procurement services to improve the efficiency and effectiveness of the acquisition system. At the same time, we find it hard to square the OMB guidance on use of pre-existing contract vehicles with DISA’s proposed creation of a parochial, redundant support services contract vehicle.

In light of the OMB guidance, DISA should immediately proceed to implement APS services by withdrawing its RFP and issuing set-aside APS statements of work under governmentwide contracts, especially, GSA Schedules, IT GWACs, and OASIS. This acquisition management action would be consistent with OMB’s April 12 memorandum.

Roger Waldron is the president of the Coalition for Government Procurement, and host of Off the Shelf on Federal News Radio.

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