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.

Two weeks ago, Part 1 of this blog series focused, in part, on how BIC MAC duplicates the Multiple Award Schedule (MAS) program. Part 1 included a “table of features” which outlined the significant convergence in key contractual terms and capabilities between BIC MAC and the MAS program.

The table showed that except for one feature, cost-reimbursement contracting, BIC MAC essentially would mirror key aspects of the MAS program. BIC MAC would provide for cost reimbursement task orders against the backdrop of the MAS program, which, currently, does not include this capability, as it is limited in scope to commercial item task orders. The blurring of lines between BIC MAC and the MAS program brings us to the focus of this blog: adding cost reimbursement capability to MAS contracts.

As readers of the FAR & Beyond blog know, adding cost reimbursement capability has long been seen as a wonderful opportunity for the General Services Administration to increase value for customer agencies. Cost reimbursement capability would enhance customer agency access to an existing base of small, medium, and large businesses. Significantly, GSA recently indicated that of the respondents to its Request for Information (RFI) for BIC MAC, over 80% (863 of 1,048 respondents) already had MAS contracts. Thus, there is already an established base of current contractors — small, medium, and large — with contracts readily available to be modified to provide cost reimbursement capability.

There is nothing in statute that limits the MAS program solely to commercial item contracting other than GSA’s decision to so constrain the program. Given GSA’s discretion on this subject, and in the face of the proposed BIC MAC follow-on to OASIS, it is time for GSA to modify the MAS program to add cost reimbursement capability.

Modifying the MAS program to establish hybrid contracts that include both commercial and cost reimbursement capabilities at the task order level has been done before. One need only look to GSA’s Alliant, OASIS, and OASIS SB contract vehicles.  Each of these contracts include both capabilities. So, the precedent has been set, and, if commercial and cost reimbursement capabilities can be leveraged for other multiple award IDIQs, then it is clear they can be leveraged for the MAS program, especially where doing so would work to increase competition, reduce contracting costs and bring greater value for customer agencies.

By modifying existing MAS contracts to include both commercial task orders and cost reimbursement task orders, GSA would be providing a “win-win-win” for customer agencies, GSA, and industry. Consider just some of the potential benefits of expanding the MAS program to include cost reimbursement task orders:

• GSA can leverage existing MAS contracting and systems infrastructures, rather than creating a duplicative, new infrastructure for BIC MAC, thereby by reducing administrative and management costs.
• GSA can provide customer agencies increased access to service capabilities by providing a new channel to thousands of MAS contractors.
• GSA can increase small business access to opportunities by allowing customer agencies to compete cost reimbursement task orders among MAS contractors. Recall that the MAS Program represents the single largest government channel for small businesses, over 30% of the dollar volume, and thus, provides an opportunity to meet a critical goal of the new administration.
• GSA can avoid the unintended consequence of unnecessary duplication of the MAS Program envisioned under the current BIC MAC construct. By so doing, GSA can promote efficiency in the expenditure of bid and proposal preparation dollars by vendors, especially during these challenging economic times.
• GSA can retain the flexibility to create OASIS and OASIS SB follow-on contract vehicles that are complimentary to each other and to the MAS program, providing targeted opportunities for firms meeting follow-on OASIS requirements, along with the ability for non-OASIS contractors to participate in the market and gain experience under the MAS Program.

In light of the foregoing, and with the challenges agencies face, it is the time to bring efficiency and creativity to contracting. Expanding the MAS Program through the addition of cost reimbursement capabilities will enhance the creation of complimentary OASIS and OASIS SB follow-on contract vehicles. More on how customer agencies have found the OASIS and OASIS SB in Part 3 of the series. GSA’s current OASIS is built to last.

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