As a preliminary matter, the existence of such a significant volume of links and sub-links, taxonomies, online training, and associated Category Management documentation and resources is not a model of clarity (indeed, we are not sure whether other material on this subject is buried in these links). It leaves observers to wonder whether, in calculating the benefits of Category Management, the “input costs” of document preparation, review, and posting, along with their associated cascading and training across government, and the administrative activity and additional personnel required, are being factored into the net costs-benefit analysis of the effort. The impact of these input costs is important to understand the true impact of the Category Management process.
Be that as it may, this blog seeks to address a lingering concern: the failure to designate the Schedules as a BIC program under Category Management. It has been determined that, because Schedules requirements are not developed by representatives from agencies across government, the Schedules program does not conform to BIC criteria.
There are five BIC criteria in the Category Management process:
Rigorous Requirements Definitions and Planning Processes
Appropriate Pricing Strategies
Data-driven Demand Management Strategies
Category and Performance Management Practices
Independent Validation and Reviews by Category Teams
The critique of the Schedules requirements definition process appears to be associated with the first criterion (Rigorous Requirements Definitions and Planning Processes). The associated sub-criteria speak to stakeholder engagement in order to address “the process of collecting and capturing the requirements.” Regarding sub-criteria, however, the following general guidance is noteworthy:
To receive a BIC designation, all five of the key requirement areas must be satisfied. However, within a key requirement area, it is not required that all sub-criteria be met. Again, document the rationale used for indicating that the key requirement is met, although one or more of the sub-criteria may not be satisfied. It may be helpful to assess the relative significance of the sub-criteria to the overall key requirement when determining the impact.
This distinction is important because it highlights the fact that, although BIC criteria are necessary to Category Management, ultimately, the government should not lose sight of its goal to have agencies operate efficiently at optimal prices. From our members’ perspective, this distinction suggests that the process should be flexible enough for the government to exploit data from other processes that serve as a proxy for the process envisioned under the criteria and sub-criteria. Such proxy data exists with the Schedules.
Indeed, even if the form of the Schedules requirements development process does not align perfectly with the BIC process, agencies’ overwhelming use of the Schedules demonstrates that the substance of the BIC process clearly is achieved. The Schedules are a premiere government contracting program with more than $32 billion in spending in the last fiscal year, and GSA, in fact, has determined that they are the largest purchasing program on the planet. Furthermore, the program is essential for helping agencies meet their socioeconomic goals, facilitating more than 38 percent, or $12.7 billion, of Schedule spending going to over 12,000 small businesses. Noteworthy is the fact that this small business spending under the Schedules exceeds the government-wide small business spending goal of 23%
It is somewhat ironic that we even need to have this discussion because the Schedules already are the de facto “Best in Class” vehicle for federal and state government contracts. For instance, NASA SEWP, coincidentally another BIC, uses Schedules pricing as a benchmark for its pricing, as does California CMAS, which states in its guide:
CMAS agreements are not established through a competitive bid process conducted by the State of California. Because of this, all pricing, products and/or services offered must have been previously bid and awarded on a Federal GSA schedule.
Multiple states also utilize the Schedules for cooperative purchasing, and there is no question that, in the face of any disaster or national emergency, the Schedules are the first choice in response contracting. In sum, the Schedules have been tested and perfected over time and recover their own costs, all without need to assign personnel and establish duplicative bureaucracies and processes.
Clearly, there are other drivers for Category Management and BIC classification, such as Spend Under Management, coordination of purchasing, reduced contact duplication, rational decision-making in investments, and facilitation of socioeconomic goals. A blog is not an adequate vehicle for a wholesale vetting of these issues, but the discussion above suggests that a significant opportunity exists under the Schedules to provide frictionless procurement if the government is willing to add agency value and mission fulfillment to process compliance in its Category Management assessments. Given the consistent performance of the Schedules program over time, its facilitation of socioeconomic goals, and its superior performance over its commercialplatform peers, Coalition members think the decision to exclude the Schedules from BIC designation needs to be reconsidered.
Unpriced schedules: Instantly promoting small business opportunities