LETTERS TO THE EDITOR

Smaller is better

I was pleased to see Jennifer Jones' article reporting the current restructuring of the U.S. Information Agency's (USIA) embassy libraries into Information Resource Centers (IRCs) ["Embassy libraries close doors to public go online " FCW July 28].

A shift from the larger high-maintenance facility to the smaller more efficient information center can only improve the quality and usability of the information. Using a structure that "mirrors an internal library maintained by the average private corporation" is an effective way to increase the productivity and the value of a library especially one that relies on telecommunications services and the Internet.

In the interest of focusing resources such as staff time and expertise the move to the IRC and the continued use of special librarians or information professionals to manage the information will enhance the value of USIA's global programs.

It has been proven in many corporate academic and government settings that relying on the skills of special librarians creates a more efficient and cost-effective approach to information management. The information professional has played an integral role in organizing information on the Internet and he or she has the requisite skills to not only locate and collect information but also to analyze evaluate organize package and present it in a way that maximizes its usefulness.

David R. Bender Executive Director Special Libraries Association

GPRA gripe

In regard to your anonymous commentary by Bureaucratus ["GPRA's effort `not working' Hill directive misguided " FCW July 14] I would not expect Bureaucratus to understand the meaning of accountability. He needs to stand and be recognized instead of hiding behind an FCW-sanctioned cloak before I'd give his writing any credence.

Bureaucratus calls GPRA another "hall of shame" for GAO and Congress and then laments the fact that "less than half of all eligible citizens vote." I ask you editors is Bureaucratus a registered voter? Your readers will never know because it isn't verifiable is that fair? Bureaucratus could say that he is but who can trust anonymity?

As GAO found versions of GPRA clearly work in other countries state governments within this country and even some U.S. federal agencies. Also GPRA is just one part of the triad. Not included in Bureaucratus' incomplete analysis is the CFO Act of 1990 (which requires audited financial statements) and the Clinger-Cohen Act of 1996.

Together these three pieces of legislation will improve the performance of federal government agencies.

Craig K. AllenWoodstock Ga.

In support of schedules

Your Aug. 11 issue carried an Op-Ed article by Paul Caggiano president of the Coalition for Government Procurement.

I too am a strong advocate for General Services Administration schedules and like Paul understand the schedules program quite well having spent a stint as did he at GSA years ago. In fact we have been experts in the schedules process since 1973. We have consulted with hundreds of firms and agencies in the GSA schedules negotiation process and the agency ordering process.

Caggiano presents the case for using the schedules very articulately. However the history and complexity of the process are understated. Schedules existed in the Commerce Department since before World War II and were transferred to GSA when it was formed under the Federal Property and Administrative Services Act of 1949. The program was an orphan of convenience until the passage of the Competition in Contracting Act in 1984. Prior to that time the program had no legislative authority.

CICA was a complex and much-needed law that is still mostly in effect despite FASA FARA and ITMRA. One political trade-off to get the law passed was the inclusion of a legislative reference to schedules as a legitimate form of procurement. CICA did this but said that schedules were competitive only when the regulations for their usage (FAR 8.4) are followed and [when] the government bought the lowest-priced product that would meet its needs. GSA likes to pretend that schedules can be used in a true-value award process. However this is not true. An agency can acquire a higher-priced product. But when doing so agencies must justify this expenditure of tax funds with a basis for paying more such as additional product features needed or better warranty periods.

GSA does a very good job of getting fair and reasonable prices. However GSA does not compete among schedules in making the awards. This is now allowed under the schedule blanket purchase agreement process and via spot pricing.

As a side note none of the extensive changes in the schedule process are the result of legislative action as part of reform but rather are administrative changes decided upon by GSA. The sole exception is the FASA law change that would allow states and cities to use the GSA schedules. This is now the subject of a large battle between trade groups and agencies and was recently repealed in the Senate. The outcome of this fight is still up in the air but it appears that states and cities will not be able to buy from the GSA schedule soon if ever.

Serious students of the procurement process and agencies using the GSA schedule need to be aware of some issues brought to court and the effects of those decisions on the program.

One important case is the Data Translation case. This case deals with the basis for schedule negotiations most-favorable customer pricing which is still in effect for most schedule groups. Of the 160 GSA schedule groups only Group 70 uses the more reasonable standard of the FAR at 15.8 "fair and reasonable." Vendors that possess a GSA schedule of any category or those considering getting one need to study the Data Translation case very carefully.

The Army just lost a very important case in federal claims court in ATA Defense Industries No. 97-382C. This case needs to be reviewed by all vendors and agencies.

The Defense Information Systems Agency bought some $400 000 worth of products from a GSA schedule and included in the order some $200 000 in products that were not on the GSA schedules. This open-market order was not synopsized in the Commerce Business Daily as required by FAR Part 5 and was declared by the court to be an illegal sole-source award. Mixing schedule and open-market orders is common and often illegal.

I applaud the general improvements that GSA has made administratively to the schedule program and I look forward to many more. After almost 40 years in the business I have never found anything complex which does not need refinement and enhancement and better training.

However GSA has moved slowly to revise FAR 8.4 and no agencies have made any attempts that I can discern to inform contracting people of the changing case law described above. GSA needs to do so yet the procurement policy people in every agency are equally neglectful.

Caggiano correctly observes that about two-thirds of all schedule resellers are small businesses. What was not revealed is that of some 1 000 vendors in Group 70 five large firms obtain about two-thirds of all schedule orders or in the case of Government Technology Services Inc. a small firm primarily sell products manufactured by large businesses.

Schedule business is great if one of four factors applies to your firm.1. You are small agile and very smart.2. You are a large firm with market dominance and a large ad budget.3. You are a small or large firm with extensive telesales or a large sales force.4. You own a product widely recognized to be the best of breed in your market.

All other firms are finding schedule business to be a tough row to hoe. As one Navy techie told a client recently "We are going to buy from vendor X and there is nothing you can do about it." Wrong. Try FAR 8.4. Schedule business is growing and if properly done is efficient and fair. Properly done is the key phrase.

Terry D. MillerPresidentGovernment Sales Consultants Inc.

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