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.

This week, the Coalition hosted an all-member meeting focused on the consolidation of the Multiple Award Schedules program. As you may recall, the General Services Administration announced in November that it will be merging the program’s 24 schedules into a single one for best value solutions. During this week’s meeting, Stephanie Shutt, the director of GSA’s MAS Program Management Office, provided members with an update and answered questions about GSA’s plans for the transition. The Coalition sincerely appreciates her open dialogue with industry, and we look forward to continuing the dialogue in the coming months.

As many of you know, the Coalition has been a strong advocate for the single schedule concept, which will help to reduce costs for both government and industry stakeholders, as well as increase competition and customer access to best value solutions. Through this approach, GSA can inject much-needed consistency into the MAS program, promote competition, and increase the delivery of best-value solutions to customer agencies. At the same time, however, there continue to be opportunities to further streamline and enhance the MAS program. In light of this consolidation effort, the Coalition believes it is time for GSA to consider another innovative improvement — a schedules telecommunications solution.

In April 2014, GSA’s Integrated Technology Service (ITS) published a white paper, “Network Services 2020 Strategy, NS2020: Defining the future of Federal Telecommunications.” Notably, the white paper set forth GSA’s future vision for providing government-wide telecommunication solutions, including a framework for what would become the agency’s Enterprise Infrastructure Solutions (EIS) contracting vehicle.

Awarded in July 2017, EIS is a 15-year, $50 billion contract vehicle that is intended to improve the way federal customers modernize aging IT and telecommunications systems. A key aspect of the vehicle is its expanded scope of work, which includes telecommunication and other IT services.

The layout of Section B of the draft RFP is instructive, providing six mandatory telecommunications-based contract line items (CLINs) that must be proposed by the vendor and accepted by the government for the vendor to be eligible for an award. Further, the vehicle also includes more than 25 optional CLINs covering a host of other services, including, but not limited to:

• Infrastructure as a Service
• Platform as a Service
• Software as a Service
• Content Delivery Network Service
• Call Center Services

Since its introduction in 2014, the Coalition has continued to raise concerns regarding the broad scope and narrow entry point (due to the mandatory telecommunication CLINs) of the EIS vehicle. Indeed, the unintended consequences of the current EIS contract structure will have significant, negative impacts on competition and innovation in the Federal IT marketplace. Moreover, it risks increasing, rather than decreasing, unnecessary duplication within the family of GSA IT contracts, as well as across the entire federal government.

The scope and structure of the EIS vehicle is of particular concern to the Coalition and its members, as it unduly restricts competition by designating several mandatory and optional solutions. Specifically, to be eligible to provide “optional” products/services under the EIS vehicle, an offerer must also provide the “mandatory” telecommunications-based solutions. Consequently, this structure eliminates the ability of numerous cloud service providers, call center providers, and equipment suppliers from competing directly for requirements under the EIS vehicle. Under these circumstances, competition is limited to a small subset of the information technology and telecommunications market.

This limitation on competition is particularly of concern when considering recent contracting decisions of the Department of Homeland Security. Specifically, DHS issued a request for information in January that sought to identify companies that would be suitable for providing contact center services. Since that time, however, DHS has informed industry stakeholders that it intends to pursue a solution via the EIS contract vehicle. Consequently, rather than utilizing the highly competitive MAS program, DHS is limiting this opportunity, which is for services that are considered “optional” under the EIS vehicle, to a subset of nine technology and telecommunications companies.

By including telecommunication services on IT Schedule 70, and thus, removing their current mandatory status, GSA could maximize competition across all cutting-edge service areas without inhibiting the ability of customer agencies to consolidate requirements at the order level. Moreover, continuous open seasons would ensure that federal customers have access to innovative technologies on an ongoing basis.

As GSA continues to focus on improving the MAS program with the implementation of the consolidated schedule, including addressing duplicative systems and SINs, the agency should consider additional opportunities to further streamline and enhance the MAS program. Moving forward, the Coalition supports GSA’s efforts to seek industry feedback and we look forward to working with all stakeholders on this timely, strategic effort.

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

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