ACT-IAC 2014 GWAC forum comments and recommendations

American Council for Technology-Industry Advisory Council (ACT-IAC) 3040 Williams Drive, Suite 500, Fairfax, VA 22031

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Advancing Government through Collaboration, Education and Action

ACT-IAC 2014 GWAC Forum Comments and Recommendations

Date Released: September 12, 2014

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Advancing Government Through Collaboration, Education and Action Page 2

American Council for Technology-Industry Advisory Council (ACT-IAC)

The American Council for Technology (ACT) is a non-profit educational organization established in 1979 to improve government through the efficient and innovative application of information technology. In 1989 ACT established the Industry Advisory Council (IAC) to bring industry and government executives together to collaborate on IT issues of interest to the Government.

ACT-IAC is a unique, public-private partnership dedicated to helping Government use technology to serve the public. The purposes of the organization are to communicate, educate, inform, and collaborate. ACT-IAC also works to promote the profession of public IT management. ACT-IAC offers a wide range of programs to accomplish these purposes.

ACT-IAC welcomes the participation of all public and private organizations committed to improving the delivery of public services through the effective and efficient use of IT. For membership and other information, visit the ACT-IAC website at www.actiac.org.

Disclaimer

This document is a summary of discussions during a recent forum conducted by ACT-IAC. This document does not – nor is it intended to – take a position on any specific course of action or proposal. This document does not – nor is it intended to – endorse or recommend any specific technology, product or vendor. The views expressed in this document do not necessarily represent the official views of ACT-IAC or those of the individuals and organizations that participated in the forum.

Copyright

©American Council for Technology, 2014. This document may not be quoted, reproduced and/or distributed unless credit is given to the American Council for Technology-Industry Advisory Council.

Further Information

For further information, contact the American Council for Technology-Industry Advisory Council at (703) 208-4800 or www.actiac.org.






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Contents

Executive Summary ................................................................................................................. 4

Discussion Questions and Outcomes ...................................................................................... 5

Question #1 – How do you successfully transition contracts onto GWACs? ........................... 5

Recommendations ................................................................................................................... 6

Question #2 – Should FAR part 17 be reworded or reconsidered for GWACs? ...................... 7

Recommendations ................................................................................................................... 8

Question #3 – How do GWACs streamline the acquisition process? ...................................... 9

Recommendations ................................................................................................................. 10

Question #4 – What are the best practices for teaming for success under GWACs? ............ 10

Recommendations ................................................................................................................. 11

Summary ............................................................................................................................... 12

Authors & Affiliations ............................................................................................................. 13




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Executive Summary

A key objective for every federal agency is to responsibly procure goods and services at the best value possible in a streamlined and efficient process. There are a variety of acquisition vehicles available for use by the government. Government-wide acquisition contracts (GWACs) are designed to enable faster, more cost-effective IT acquisition processes and utilize trained and experienced information technology (IT) and contracting staff, with the purpose of assisting agencies in accomplishing this goal in a timely manner.

To assess the strategies on transitioning and leveraging GWACs to compete and be awarded IT acquisition contracts, ACT-IAC co-hosted a GWAC forum with the National Institutes of Health (NIH) Information Technology Acquisition and Assessment Center (NITAAC) to discuss processes and procedures that need to be modified and to share industry and government recommendations and lessons learned when using or planning to use a GWAC. The forum included perspectives from the Office of Management and Budget and three GWACs – NITAAC, NASA SEWP, and GSA Alliant, and featured working table discussions among the 188 forum participants on four key questions.

The main forum objectives were to assess new strategies for transitioning existing contracts to GWACs, determine if any barriers existed along with recommendations to mitigate, and to obtain existing or recommended insights and best practices to help agencies access the technologies and qualified contractors needed to achieve their goals and mission.

ACT-IAC is pleased to provide the Office of Management and Budget (OMB) a synopsis of the forum’s discussions and recommendations. We hope these comments from both industry and government will be to OMB in modifying existing regulations, correcting misconceptions, and enhancing the visibility of GWAC efficiencies and cost savings to federal agencies.

Summary Overview of OMB and Panel Discussion

Matthew Blum, Associate Administrator, Office of Federal Procurement Policy, Office of Management and Budget, stated “GWACs are the forefront on evolution of modern day contracting” during his remarks that opened the forum. They leverage buying power, consolidate resources and processes, and save money. The future of GWACs will continue to focus on customer needs and best value options. With the same management GWACs have in place today, GWACs will continue to offer flexible customer-centric options that meet their expectations. The ultimate outcome in regard to contract selection will always be the “best value option for the customer”.

A panel comprised of the leads of NIH NITAAC, NASA SEWP, and GSA Alliant concurred with Mr. Blum that GWACs will flourish if the customer feels their service is more efficient, effective, flexible, easier, timely, and customized to meet their needs. The panel indicated competition was healthy but also that more agencies should be directed to leverage the value and benefit of GWACs as opposed to creating their own internal IDIQs.

Discussion evolved around the perception of FAR part 17 that contracting officers felt compelled to write a determination to use an interagency contract like a GWAC. To the




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agency contracting office, this is perceived as a risk in using a contract vehicle outside of their agency. A recommendation was made with audience concurrence that guidance should be included in the FAR to always consider GWACs as part of the analysis in selecting a contract vehicle and to require an explanation if a GWAC is not selected as a best value vehicle. In addition, as part of this process, suggestions were made to simplify the determination and findings (D&F) analysis in order to expedite the process in selecting the best value contract vehicle

Discussion Questions and Outcomes

Included with each question is the description and objectives of the discussion followed by the collective recommendations and suggestion from each working table.

Question #1 – How do you successfully transition contracts onto GWACs?

Description: transitioning services is a complex process involving many changes in processes and procedures. Overall, agency program and contracting staff feel that perceived changes to existing contract vehicles represent a risk.

GWACs were developed to support IT services and commodities across the Federal Government. GWACs provide the program and contracting office with qualified IT, contracts, and support staff who are dedicated to providing full scale acquisition services and support.

Objectives of Discussion

Obtain suggestions and recommendations from the table discussions as to the value and benefits of using GWACs.

Determine how to mitigate transition risk. Share success stories where agencies have transitioned their internal contract vehicle

to a GWAC. Assess the value of GWAC performance measurements during the transition.

Key Comments Made During Working Sessions

Reasons to transition to GWACs:

o Saves time,

o Low risk with experienced IT and CO staff to support the procurement process,

o Lower cost,

o Qualified vetted vendors,

o Customer support services,

o Pre-negotiated contract rates below market value,

o Large number of labor categories to support any type of IT procurement,

o Flexibility,

o Streamlined processes and efficiencies,




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o Transparency of information through FAQs, community action groups (CAGs), vendor meetings, and

o Less protest risk and no protests under $10M.

Perceived risks from agencies transitioning to a GWAC versus their own procurement vehicle:

o Loss of control at the agency level,

o Perception of higher cost using an outside vehicle,

o Concern over GWAC contract fees and misunderstanding of optional assisted acquisition fees,

o Include GWACs in the agency business acquisition approach/business case review,

o Conduct a thorough cost /benefit analysis to assess the full lifecycle cost trade-off between using an agency contract vehicle and a GWAC,

o Add “what if” type scenarios, such as “what if this award is protested?”, to the acquisition approach risk planning,

o Terms and conditions don’t conform to the agency, and

o Perceived understanding that agencies are committed to their internal contract vehicles and must justify the use of GWACs.

Success stories in transitioning to GWACs:

o Navy,

o Air Force,

o Army in Korea,

o Defense Health, and

o OPM.

Recommendations

Provide performance metrics to assess timeliness, number of bids by industry, and number of different agencies using GWACs.

Determine a process to record any “soft” savings by using a GWAC.

Educate government program and acquisition staff on the value and benefits and then have these individuals converse with their counterparts in different agencies.

Continue to enhance and provide templates and examples that provide ease of use and transition.

Utilize RFIs to position vehicles during market research phase that ask questions on preferred contract vehicles. Contracting officers might consider changing to a GWAC if they receive multiple responses recommending them.




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Increase the number of responses by industry to develop a larger pool of competitors for government to review.

Consider discussing with government acquisition staff a shorter response from industry to encourage a higher number of responses.

Continue events and forums on GWACs that facilitate discussion between industry and government.

When GWACs are not selected question the reason why. Based on the reason, determine if changes are needed.

Educate government that industry can meet with government during market research phase.

Meet at higher levels within the agency to foster a top-down education.

Consider a conference with agencies currently using a GWAC to determine their level of customer satisfaction and/or recommendations.

Utilize chat discussions, social media, webinars, and other tools to communicate.

Develop recommendations to contracting officers on how GWACs mitigate contracting issues.

Promote success stories.

Question #2 – Should FAR part 17 be reworded or reconsidered for GWACs?

Description: on direct acquisitions, FAR subpart 17.502-1 states that prior to placing an order against another agency’s indefinite-delivery vehicle, the requesting agency shall make a determination that use of another agency’s contract vehicle is the best procurement approach and shall obtain the concurrence of the requesting agency’s responsible contracts office.

Objectives of Discussion:

Assess the original intent of FAR subpart 17.5 as it relates to IDIQs or GWACs. Assess the current impact of FAR subpart 17.5 on the use of GWACs. Determine if the working group feels FAR subpart 17.5 should be modified. Assess whether there is a proliferation of existing internal agency contract vehicles

limiting the use of GWACs.

Key Comments Made During Working Sessions:

General: o Government participants felt the business case process was cumbersome.

Consideration should be given to changing the business case preparation process to simplify the analysis of various contract vehicles in a more expedient manner.

o Depending on the contracting officer and agency, there are different interpretations of FAR subpart 17.5. Clarity needs to be achieved through a rewording or a directive memorandum from OMB.




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o Contracting officers may not understand all the parameters of the FAR and may not think certain aspects apply.

o Contracting officers feel there is an extra administrative burden by evaluating multiple contract vehicles and simply resort to the current contract processes in place.

o Language from the FAR comes across as vague. o One agency required a penalty fee if a GWAC was used versus their own

internal vehicle. o Blanket purchase agreements (BPAs) are competing with GWACs. BPAs are

readily used to consolidate small contracts into one vehicle where contracting officers feel that an existing GWAC isn’t suitable. However, contracting officers want the ability to issue BPA-like vehicles under GWACs for repetitive agency requirements that would allow different contracting officers to issue task/delivery orders against it (i.e., strategic sourcing).

Reason for not using GWACs: o Agencies have their own internal contract vehicles and IDIQs. o Lack of understanding and knowledge of GWACs. o Lack of program and acquisition staff education. o Comfortable with the current contracting vehicles; not interested in change. o The agency does not see the incumbent listed on the contract. o Concern over contract fees; misunderstanding of optional assisted acquisition

fees. o Perception that agencies must use complicated FAR part 15 procedures to

place orders under GWACs. o Lack of concrete guidance on using a streamlined approach to issue orders

under GWACs. o Heavy emphasis placed on small business utilization goals. o Inability to reach their current known contractors or those contractors who

possess unique and specialized experience or capabilities.

Recommendations

Clarifications need to be made on what falls under the interagency umbrellas of MAC, GWAC, IA, and FSS.

Develop a uniform approach from OMB on using GWACs.

Consider a federal goal for GWAC use.

FAR subpart 17.5 should be changed to read: “the requesting agency shall evaluate all potential contract vehicles to assess the best procurement approach. Concurrence shall be obtained from the responsible contracting office when GWAC programs are not being used.”

Consider a separate section in the FAR for GWACs.

Consider expanding FAR part 39 for GWACs and ordering contracting officers to have the ability to issue BPA-like vehicles under GWACs.




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Create an arbitration or review panel to review the findings for contract vehicle selection that is evaluated based on need and best value.

Obtain top level buy-in at CIO level.

List the benefits of streamlining the acquisition process for GWACs.

Provide more guidance on streamlined approaches that keep agencies from using FAR part 15 procedures.

All agencies should be consistent in their interpretation and understanding of FAR subpart 17.5.

Create templates to assist contracting officers in making the decision to use GWACs.

Create factsheets that explain FAR part 17.

Assist in developing a fair and open selection process that enables viewing of all GWACS and internal contracts to determine which one offers the best value.

Add GWAC training to the Federal Acquisition Certification in Contracting (FAC-C) training requirements, Defense Acquisition University (DAU) or Federal Acquisition Institute (FAI) that covers all GWACs evenly.

Question #3 – How do GWACs streamline the acquisition process?

Description: GWACs have been approved by OMB to assist multiple agencies in achieving their acquisition objectives while improving the level of customer service. The OMB-approved GWACs are known entities, have skilled acquisition staff, and provide support services to enable seamless, easy-to-use acquisition processes.


Obtain a clearer understanding of the services and support provided by GWAC acquisition.

Obtain recommendations and suggestions to further streamline the GWAC acquisition process.

Assess whether the GWAC processes and services improve the services to your clients and/or firm.

Assess whether there are common uses and/or misconceptions regarding GWAC streamlining.

Key Comments Made During Working Session:

Barrier to GWACs and streamlining: o Contracting offices still need to justify the fee for using a GWAC. o Obtaining approval from the funding office to use a GWAC. o When the same RFI is released on multiple vehicles, firms are not responding,

not knowing whether these are “real” opportunities that will result in a RFP.

Elements contributing to streamlining: o Timely customer service support responding to questions and issues, o Templates for creating SOWs, PWS, RFIs, etc., o Honest broker between government and industry,




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o Fair, open competition, o Better buying power, o Well defined functional areas, o Improved timeframe to task order award since some evaluation criteria has

been previously vetted at the master contract level, o Assisting customers in developing a SOW and requirements that are compliant, o Bidding to multiple vendors through one system saves time in sending and

responding to multiple independent bids, o Efficiency of ordering process and system capabilities, o Ability to select from various vetted socio-economic firms, o Create clear small business guidelines under GWACs to remove duplication, o GWAC PMO at the contract vehicle agency or at the vendor provide an added

layer of discipline and oversight on contracts, o All contracts are organized and treated in the same consistent manner, clearly

outlining requirements, scope of work, and evaluation criteria, and o Control remains with the customer throughout the procurement.

Recommendations

Educate people of authority.

Educate the senior acquisition staff on how to choose the best value vehicle.

Create clear small business guidelines under GWACs to remove duplication.

Compare metrics of using GWACs to other acquisition strategies (time to issue and award task orders, cost to acquire, protest frequency – all, denied, sustained, past performance average rating in CPARs).

Question #4 – What are the best practices for teaming for success under GWACs?

Description: each of the prime GWAC contract holders either have an existing teaming arrangement, propose new teaming partners based on the procurement, or add/replace teaming partners based on the level of support. Contract holders, through their experience, have developed best practices for utilizing teaming partners to respond to task order requirements. The end result is faster bid and no-bid decisions, decreased proposal response cycles, and increased wins resulting in revenue


Share best practice models or lessons learned for large and small business teams that improve the number of responses and proposal responses in general.

Understand the value and benefit of teaming. Determine how best practices lead to a positive outcome.

Key Comments Made During Working Session:

Issues related to teaming:




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o The opportunity acquisition strategy directs teaming, so the sooner it is set and communicated, the better.

o Too little lead time from procurements release to find and vet a suitable teaming partner.

o Without a pipeline, primes can’t efficiently plan ahead for teaming. o Small business firms tend to distribute only their corporate qualifications to primes

which do not justify the value and benefit they bring to a team. Many primes look at these emails as spam.

o The decision for teaming rests with the prime; GWACs only provide the listing of contractors and not recommendations. In addition, primes have to evaluate the value of adding incumbents to the team which at times can be positive and at other times negative.

o Some primes have developed a teaming relationship with their original subcontractors that offer those subs the right of first refusal for any task order released. Therefore, more qualified teaming partners for a particular bid would not be added to the team. The prime may opt to bid without presenting the most qualified team.

o Inability to develop a qualified team when initial RFI is released out on multiple contract vehicles. RFI respondents can lose sight of the RFP and fail to team if an RFP is released on a vehicle that contractor does not prime.

o Difficult and expensive to establish teams when the acquisition strategy is released only in the RFP.

o Some agencies are concerned that if a large firm that subcontracts to a small firm terminates its relationship that the small firm may not be able to perform on the contract.

o Teaming partners need to evaluate the reputation of the primes prior to subcontracting.

Recommendations

For those interested in teaming, know the customer and bring qualified or niche skills to the prime. It is of value for the teaming partner to know the requirements or tools, know the agency, provide niche technology, have strong past performance, and have the ability to offer the right technical competency with well qualified staff.

Reach out to other contractors who are awardees on the vehicle to understand their core capabilities and customer knowledge.

Conduct face-to-face interviews and open conversations with current and future teaming partners.

Filter out unresponsive partners and replace with those who are going to support the GWAC vehicle, customer outreach, and proposal support.

Utilize the RFI or Sources Sought notice as a means to identify and build a team and subsequently meet with customers.




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Have government utilize the RFI or Sources Sought notice to define more information about the procurement in order for primes to select the best qualified teaming partners.

Establish more government/industry matchmaking events to encourage early meetings and discussions.

Encourage vendor-to-vendor sharing events.

Provide more focused industry days, not just broad events limited to business card exchanges.

Consider sharing task orders (only the scope of work) more openly with other contract holder primes or on FBO. As an example, a designated task order to SDVOSB would be shared with all prime holders on the contract vehicle. This would offer the set-aside company, i.e., the SDVOSB in this example, to obtain inquiries for teaming from interested firms. This process would increase bidding and competition.

Ensure all RFI respondents are notified of final RFP acquisition strategy to allow for teaming opportunities when unable to prime.

Industry needs to develop a business and marketing plan for GWACs that includes performance metrics and project outcomes.

For future on-ramping, consider a contractor teaming agreement or a joint venture.

Each proposal response needs to be viewed as an independent response. Develop the best team that meets the client’s requirements.

Primes should consider developing a vendor profile data base that easily can be searched for firms who provide the experience, requirements, and skills to support the prime on a bid.

Larger firms should consider developing mentoring relationships with small firms to solidify teaming arrangements.

Firms interested in being added to an already existing team need to bring an opportunity to the prime to be considered.

Allow post award teaming and subcontracting across the board in order to allow incumbents, small business, and other firms who were not part of the original proposal to participate in the response.

Require the primes to provide copies of all communications with the government to all subcontractors and teaming partners, including RFIs, RFQs, etc.

Summary

The interaction and discussion between industry and government provides an excellent forum for exchanging ideas and suggestions that can improve existing processes, procedures, and regulations. The working table discussions enabled both government and industry attendees to understand potential barriers and share lessons learned, best practices, and creative ideas for improving GWAC operations and processes.

What has been obtained from these discussions is that GWACs are still not well known by both the program and acquisition staff. Education of agency leadership, acquisition, and program staff and clarifying strategic sourcing needs to continue in an ongoing manner to




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provide the value and benefit GWACs bring to procurement processes. In addition, clarification is needed regarding the application of FAR part 17 to GWACs as interpretation of FAR subpart 17.5 varies among contracting offices. Specifically, the section stating: “shall make a determination that use of another agency’s contract vehicle is the best procurement approach” is interpreted by the contracts staff as they must develop a business case to consider any “outside of the agency” contract vehicles, such as a GWAC. Many of the working group participants recommended review of the FAR subpart 17.5 language and consideration given for further clarification to enable a broader assessment of multiple contract vehicles, internal and external, and then select the one that provides the best value.

Author & Affiliations

Carol S. Miller, IAC Executive Committee Miller Consulting Group


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ACT-IAC 2014 GWAC forum comments and recommendations

Government & Nonprofit