Unpriced schedules: Instantly promoting small business opportunities

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 July 2, the General Services Administration announced the cancellation of the Alliant 2 Small Business solicitation. The cancellation represents a major change in the federal market for small business technology firms, eliminating a channel that accounted for more than $8 billion in spending over the life of the contract by customer agencies contracting with those firms.

The original Alliant SB contracts were awarded back in 2009 and expired in 2019. Alliant SB was a “Best-in-Class” contract, as designated by the Office of Management and Budget.

With the cancellation of the follow-on procurement, there is a significant, potentially long-term, gap in federal market opportunities for small IT services firms. Although GSA’s announcement highlighted plans for a new, enhanced small business GWAC program, there little insight regarding GSA’s implantation plan or timeline. GSA did indicate that “following additional market research with customer agencies[,] the future GWAC program strategy will include new solicitations” for pools of small businesses across multiple socio-economic categories. GSA did indicate that the follow-on 8(a) STARS procurement would be part of the overall strategy and, as promised, earlier this week GSA released the 8(a) STARS III request for proposals (RFP).

Notwithstanding the release the 8(a) STARS III RFP, the cancellation of Alliant 2 SB and the corresponding uncertainty surrounding the future of GSA’s small business GWAC portfolio already is roiling the market. At this critical time, it is incumbent on GSA to reach out publicly to customer agencies and the IT small business community and set forth the rationale (e.g. changed requirements) that prompted cancelling the Alliant 2 SB solicitation. More importantly, GSA need to lay out, publicly and proactively, the way forward in managing its portfolio of GWACs and how it plans on replacing Alliant 2 SB. Details matter for businesses investing in the federal market. The sooner GSA presents its plan, the sooner industry and customer agencies can adapt/adjust to the new dynamic. The Coalition stands ready to engage with GSA and all stakeholders on the future of small business interagency contracting opportunities.

In this regard, the Coalition again highlights that chief among the strategic opportunities for small businesses is the unpriced schedules for services. Unpriced schedules will promote/enhance opportunities for small businesses immediately. In addition, unpriced schedules will eliminate costly barriers to entry in the negotiation and award of MAS contracts, enhancing access to small business innovation from the commercial IT market. Unpriced schedules also will reduce burdensome contract administrative and compliance costs for small businesses, allowing them to focus resources on task order competition and performance, where it really counts.

Simply put, unpriced schedules will be a great multiplier in effectively bringing competition, innovation, and small business capability from the commercial market to customer agencies. As such, they will be a win for small businesses, customer agencies, and GSA, especially considering that GSA has a strong small business MAS program from which to launch the promotion of additional opportunities for small business. For example, in FY19, IT Schedule 70 accounted for over $5.5 billion (over 35% of total IT Schedule 70 dollars) in customer agency purchases from small businesses, which is more than all of GSA’s small business GWACs combined. Indeed, IT Schedule 70 remains the unsung hero of IT small business spending.

GSA has the organic tools to put this effort in place quickly, as it has exclusive statutory authority for the MAS program, the concomitant regulatory framework and flexibility to implement the unpriced schedules via the General Services Acquisition Regulation, and the use/issuance of special ordering procedures. The adoption of unpriced schedules for hourly rate services, combined with pricing reform for cloud services, would be a powerful, future forward statement in providing access to cutting edge technologies/capabilities from the commercial market. Moreover, there is precedent for such an approach. Professional IT services would not be on schedule but for GSA exercising its exclusive program authority to add hourly rate services to schedule contracts and establishing special ordering procedures for customer agency task order competitions.

As a final note, it should be noted that the cancellation of Alliant 2 SB also opens the door for the National Institute for Health’s CIO-SP4, the proposed follow-on to the current CIO-SP3 GWAC. Significantly, as currently structured, CIO-SP4 will be a single contract vehicle including both small and other than small businesses. To maximize opportunities for small businesses and increase efficient and effective access for customer agencies, CIO-SP4 should move to split the proposed procurement into separate contract vehicles, one small business and one other than small businesses. This structure mirrors the successful approach taken by the original Alliant SB contract vehicle. Coalition members, small and other than small, look forward to engaging with NIH on this critical market entry opportunity, and we remain committed to assisting GSA with its efforts to implement the unpriced schedule.

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