Sisti: How much is too much?

Procurement reform never intended such administrative duplication and cost

Like the changing of the seasons, major procurement reform has its own rhythm. It follows a 10-year cycle that allows time for users to assimilate changes and assess their value. Recently proposed statutory changes and debate over the use of governmentwide acquisition contracts (GWAC), however, appear to be rooted in something

more than mere cyclical changes.

A controversy surrounds a contracting process some perceive as burdensome. Increasingly, multiple long-term GWAC solicitations with substantially overlapping requirements seek multiple awardees. The awardees receive nominal minimum revenue guarantees, high revenue ceilings and the privilege to compete for potential task orders.

This multi-GWAC environment has the potential to distort the buying process. Single, multi-award GWAC competitions with low minimum revenue guarantees and no upfront association of requirements with task orders already leave awardees with only task order "hunting licenses."

Multiple GWAC solicitations containing substantially similar requirements can turn the process into a shell game, compelling vendors to pursue all such contracts to ensure they can compete for tasks issued under any contract.

Procurement reform never intended such administrative duplication and cost. Multiple awards sought to introduce competitive pressure into the indefinite-delivery, indefinite-quantity contracting process. The use of multiple awards, however, was to be weighed against the existence of sufficient administrative resources, administration costs and taxpayers' best interests.

The potential for waste is exacerbated by the fact that, collectively, GWACs can resemble poor facsimiles of the successful General Services Administration schedules program, which contains its own proven efficiencies and multiple-award administrative expertise.

Moreover, buying distortions associated with a multi-GWAC environment may mask more fundamental management, not procurement, problems. Calls for oversight and redress, then, could focus erroneously on amendments to the process — or worse, the repeal of reforms as a solution. That result would be unfortunate. It would leave us to continue confronting management problems without even the administrative benefits of reform.

GWACs can facilitate flexible acquisition under unique scenarios and/or to address surge capacity needs, the dynamic nature of the information technology market and changing technology. Their use, however, should be tempered by the potential drain on resources, market confusion and cost barriers to vendors in the government market.

Government officials should weigh all costs associated with GWACs, including duplicating contracting staffs and other resources, agency-contracted administration support, contractor duplication of effort and the costs of diminished competition associated with increased barriers to market entry. If the benefits do not outweigh the costs, agencies should avoid GWACs.

Sisti is vice president for law and policy at the Washington Management Group. Formerly, he was counsel to the Senate Governmental Affairs Committee.

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