Tuesday Insight – June 1st, 2021

Jun 2, 2021

FSS BPAs: Back to the Future or ‘Déjà vu all over again!’

On May 13, the General Services Administration issued a request for information (RFI) seeking industry feedback on a “governmentwide cloud acquisition strategy and Blanket Purchase Agreement.” The RFI details the acquisition strategy to deliver a multiple award BPA for commercial software-as-a-service (SaaS), platform-as-a-service (PaaS), and infrastructure-as-a-service (IaaS).

The RFI raises a number of questions:

First, on page 5 of the RFI, GSA compares the generic governmentwide multiple award BPA strategy with other acquisition tools by highlighting the negative features of these tools, including single award BPAs and GSA’s IT GWACs. It is perplexing that GSA would characterize these key acquisition tools in such a manner, especially when certain GSA IT GWACs are identified as Best in Class contracts.

What message is being sent to its customer agencies and industry partners regarding these tools? Make no mistake, Coalition for Government Procurement members strongly support the Federal Supply Schedule (FSS) program. GSA’s industry partners, however, also understand that single award BPAs and the IT GWACs play critical, positive roles in supporting customer agency mission requirements. Unfortunately, the RFI creates the impression that GSA is competing against itself, undercutting its overall approach to the federal customer.

Second, the RFI and previous generic, governmentwide BPAs raise questions regarding additional fees charged to customer agencies and the addition of BPA contract terms/features that are not included in the underlying FSS contracts. Additional fees charged for the creation of generic, governmentwide BPAs raise questions regarding GSA’s overall fee structure. Perhaps it is time for an overarching review of the fees and operating costs to determine whether the Industrial Funding Fee is set at the appropriate level. With regard to supplemental BPA terms that are not included in the underlying FSS contracts, GSA should engage in dialogue with its industry partners and customers as to whether these terms should be negotiated at the FSS contract level. Too often, it appears one justification to executing a governmentwide BPA is to add a standard feature that could have been included at the contract level.

Finally, generic, governmentwide multiple-award BPAs create vertical contract duplication (that is, redundancy in the administrative processes and terms of the contract), increasing costs for FSS contractors, GSA, and customer agencies. FSS contractors must negotiate and administer their FSS contracts, compete for and manage a generic, governmentwide multiple award BPA, and, ultimately, compete for and manage a task order issued under the BPA. Why not ensure the FSS contracts include the terms/features responsive to the federal market and then compete a task order under the contracts? A generic, governmentwide, multiple-award BPA creates an additional layer of cost, administration, and process that increases costs for all.

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