Public Meeting Transactional Data Reporting Gene neral S Services Adm dminis nistratio ion Proposed R Rule 2013 2013-G504, T Trans nsactiona nal Data R Repo porting ing Apri ril 17, 17, 2015 2015 Publ ublic M Meeting be begins pr promptly ly a at 9 a.m. E EST
WELCOME & OPENING REMARKS JEFF FFRE REY K K. K KOSES SENIOR PROCUREMENT EXECUTIVE, GENERAL SERVICES ADMINISTRATION
CATEGORY MANAGEMENT ANNE NNE R RUNG ADMINISTRATOR, OFFICE OF FEDERAL PROCUREMENT POLICY
MAS TRANSFORMATION IMPLEMENTATION KEV EVIN Y YOUEL EL-PA PAGE DEPUTY COMMISSIONER FEDERAL ACQUISITION SERVICE, GENERAL SERVICES ADMINISTRATION
BACKGROUND & CONTEXT MA MARK J K J. LEE DEPUTY DIRECTOR, OFFICE OF GENERAL SERVICES ACQUISITION POLICY, INTEGRITY & WORKFORCE GENERAL SERVICES ADMINISTRATION
Why are we having this conversation?
Background and Context on Key Aspects of the Proposed Rule Use o of Transactional Data i in Office Supplies 2 2 (OS OS2) Burden A Analysis Analysis o of B Basis of A Award Requirement ( (BOA) of t the P Price ce R Reduct ction Clause (PR PRC) Alternative ves Multiple Award Sch chedules ( (MAS) Pi Pilot
OS2 implementation of Horizontal Price Analysis Techniques and Dynamic Pricing demonstrates how substantial savings rates can be achieved
Comparison of OS2 Pre-Dynamic Pricing (November 2012 - January 2013) and Dynamic Pricing Savings Rates (June 2013 - present)
Cumulative OS2 Indirect Savings
Current Reporting Burden under Price Reductions Clause Gathering transactional data could negate the need for the Price Reductions clause and its associated reporting burden: Estimated Reporting Burden of Price Reductions Clause* No. o. of of Respo ponses es p per er Total A l Annua nnual l Avg. B Burde den H Hour urs Burden en Total B l Burden H n Hour urs Respo ponses es Responden ent Respo ponses es per er R Respo pons nse Training 16,000 1 16,000 4 64,000 000 Training Administration 16,000 1 16,000 5 80,000 000 Compliance Systems 3,200 1 3,200 55 176, 6,000 000 (heavier lift) Compliance Systems 12,800 1 12,800 30 384, 4,000 000 (lighter lift) Negotiations 19,000 1 19,000 7 133, 3,000 000 Audits 70 1 70 445 31,150 150 Total B Burde den H n Hour urs 19,000 00 1 19,000 000 46 46 868, 8,150 150 Annual burden hours to be superseded with new policy *Reporting burden is based on estimated burden from Price Reductions Clause Submission for OMB Review, 9/20/2012: https://federalregister.gov/a/2012-23137
Distribution of Vendor Sales The majority of MAS and non-MAS vendors had sales under $2 million in FY13 Distribution of MAS and non-MAS Contractor Sales, FY13 Median sales for MAS contractors: $33,000 (total vendors: 17,816) 60% MAS Vendors 50% Median sales for non-MAS contractors: $1.4M (total vendors: 477) 40% % of Vendors 30% 51 MAS vendors (0.6%) and 18 non-MAS vendors (4%) had sales over $50M in FY13 20% Non-MAS Vendors 10% 0% $0 $1 $2 $3 $4 $5 $6 $7 $8 $9 $10 $11 $12 $13 $14 $15 $16 $17 $18 $19 $20 >$20 FY13 Vendor Sales (millions)
Current vs. New Reporting Burden Comparison Cur urren ent R Repo portin ing B Burden en New R ew Repo portin ing B Bur urde den Saving ings (Pric ice R Reduc ductio ions ns C Claus use) e) (Pric icin ing Po Policy)* (New ew – Curren ent B Burden en) Average Annual 45.7 hours 6.3 hours 39. 39.4 hours rs Burden per Vendor (12.3 hours in year 1) (33.4 hours in year 1) $3,108 $430 $2, $2,67 678 ($838 in year 1) ($2,270 in year 1) Aggregate Annual 868,150 hours 115,631 hours 752, 752,519 19 h hours Burden (225,389 hours in year 1) (642,761 hours in year 1) $59,034,200 $7,862,942 $51, $51,171 71,25 258 ($15,326,486 in year 1) ($43,707,714 in year 1) By s super persedin eding c current r repo porting ing r requir equiremen ents, t the p e proposed t ed transactio ional d l data repo eportin ing g rule i ule is estim imated t to r result ult i in a net et b bur urde den r redu ductio ion o of about 7 752,000 h hour urs / / $51 millio lion p n per er yea ear *Year 1 under new pricing policy includes one-time burden for setting up reporting systems.
Reasons for Multiple Award Schedules (MAS) Price Reduction (PR) Modifications (FY14 as of August 2014) 51, 5% 33, 3% 33 PR modifications, representing 3% 116, 12% of the total, resulted from BOA pricing changes 16, 2% Reasons for Price Reductions Basis of Award (BOA) Pricing Change Commercial Pricelist (CPL)/Market Rate Pricing Change Other: Corrected Errors, Industrial Funding Fee (IFF) miscalculations, etc. Temporary Price Reduction - e.g. Promotions Voluntary Price Reduction 750, 78% Data Source: FSS19 Database Date Range: Awarded PR Mods from Oct - Aug Data Includes the following Schedules: 66, 84, 70, 899, 738 II, 874 V, 874, 871, 00CORP
Alternatives that were considered Upda pdate GSA order ering t tools ( (i.e. e. GSA Advantage, e, eBuy uy, a and nd Reverse A Auc uctio ions) and nd requ quir ire us use for a all orders Connections to agency specific contract writing and financial systems would need to be established Significant investment and upgrades would be needed to these applications GSA SmartPay Program data Less than 1% % of procurements are made using the purchase card Coll llect data f from om c custom omer a agencie cies Agencies do not store and collect this data in a manner that can be shared readily with GSA
MAS Transactional Data Reporting Implementation Pilot Sco cope Commercial products and commoditized services Partic icipatio ion Contractor participation is mandatory on select Schedules These contractors would not be subject to the BOA requirements of the PRC Evalua luatio ion n of pi pilot Clearly defined metrics such as savings rate, customer satisfaction, small business utilization, and commercial benchmarks GSA would seek stakeholder feedback on pilot experience Category M Mana nager a and C nd Contracting O Officer R Roles Software, T Tools, a and nd Train ining
Public Meeting Process Public M c Meeti ting P Proce ocess 15 Minute Presentations; Each Presentation followed by 15 Minutes of Questions Transcripts from today’s discussion will be posted on Regulations.gov Presenters’ Panel will conclude the meeting GSA is here to listen and learn Thi his m meeting i is pa part of a an n ong ngoing ing di dialogue ue Major themes will be captured by GSA’s Transactional Data Reporting Policy Team Public Comments collected from March 3, 2015 to May 4, 2015 Implementation updates available on interact.gsa.gov GSA will reconcile e all commen ents recei eived ed in response t e to t the p proposed ed r rule Comment reconciliation will begin after May 4, 2015 GSA will continue to work collaboratively with all interested stakeholders
Facilitator Roles The public meeting is an opportunity for everyone to listen and learn from the diverse viewpoints of the federal acquisition community. Ensure a e all vi views a are e heard Adher ere t e to the he s sche hedu dule led agenda da Mov ove the dialog ogue f for orward
Ground Rules 1. 1. Brie ief & & Concise Q Que uestio ions a and nd Ans nswers In-person attendees raise your hands. Virtual attendees enter your questions in the Q&A pod of GSA’s Virtual Meeting Space Questions should request clarification on the views from the presentations Facilitators will alternate between in-person and virtual attendees 2. 2. Toda day’s di discussion i n is abo bout getting ing c clarification f n from pr presenters Provide overall comments on the proposed rule in the Federal Register 3. 3. Hold your que questio ions dur during pr presentatio ions ns
OMB & GSA Panel 15 Minut nute o oppo pportun unity t to ask abo bout the he de develo lopment of t the he pr proposed d rul ule and t nd the he imple plementatio ion
15 MINUTE BREAK
Office of Inspector General U.S. General Services Administration Public Meeting Presentation Transactional Data Reporting: GSAR Case 2013-G504 Brian Gibson, Office of Audits
GSA Office of Inspector General The GSA Office of Inspector General supports the collection and use of transactional data as an additional tool for contracting officers. However, it will not provide the government with the price protections currently afforded under the Price Reductions clause. We have four main areas of concern.
GSA Office of Inspector General CONCERN ONE The proposed rule does not justify the elimination of the government’s price protections under the Price Reductions clause.
GSA Office of Inspector General CONCERN ONE – DETAILS The proposed alternate Price Reductions clause removes all significant price protections – not just the basis of award tracking requirement.
GSA Office of Inspector General CONCERN ONE – DETAILS As currently proposed, there is no contractual requirement for contractors to lower their prices offered to the government based upon the transactional data reported.
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