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Published Oct 02, 21
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HORAN. GSA Search Engine Ranker Software. Well, the method I would like then to figure it out is if it in fact produces a better value, finest worth to the government, considering the cost to the contractors. I do not think they can do that based on the manner in which the proposed rule is executed here.

Little organizations are known for the included value they can offer agencies with advantages such as client service - GSA Search Engine Ranker. Mr. GSA Search Engine Ranker Software. Horan, you specified in your testament that the brand-new rule does not account for such included worth. Again, that it might be-- the procurement could be driven to low cost just, and as an outcome of that, the professionals who use some of these other terms and services that supply finest value will lose sales at a minimum, perhaps be driven out of the market.

Mr. TAKAI. Because they are out of business or they are simply not bidding any longer? Mr. HORAN. Since they are out of the service. I mean, there are other problems. Because there is such pressure on contracting officers to take a look at only low price that sometimes they will leave out factor to consider of finest worth but ultimately, I think they might be out of the company.

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TAKAI. Okay, thank you (GSA Search Engine Ranker Software). The ratio for government procurement study in its survey, small companies indicate that it would handle average 232 hours to adhere to the GSA's proposed guideline. Mr. Stanford, has your business done its own price quote on the hours it will take to adhere to the brand-new requirement, and do you find the results of the study to be more precise than GSA's own analysis? Mr.

We have not. And while we have actually taken a look at their research study and the ABA work, we are likewise encouraged in accepting their conclusion due to the fact that likewise SBA Office of Advocacy and GSA's own inspector basic figured out that those costs appear understated. Mr. TAKAI. Their, suggesting the coalition, not GSA's? Mr. STANFORD.

Other than our spin on compliance, can you talk about some other expenses that companies like yours will have to face due to the fact that of this rule? I will not speak to our business individually, however speaking to the companies we work with as they enter the federal market, the expenses beyond compliance are-- for little organizations are preliminary expenses up front.

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Mentioning the expense of upgrading its data systems, GSA is proposing to ask vendors to report to GSA the details of what was purchased through GSA. This resembles asking retailers selling through Amazon to report to Amazon what it sold, through Amazon. To take this example one action further, Amazon would then utilize that info to market rates to other consumers, on Amazon.

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While not an ideal contrast, GSA in lots of ways runs as an Amazon-like part of the acquisition process. The intent behind this rule is seeking to make a best-in-class contracting market. GSA has actually decided to pass on investing in a data collection system that might gather this info automatically.



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II. The Rule Imposes a Significant, Underestimated, and Unnecessary Burden GSA approximates that it will take 6 hours for a contractor to achieve all jobs required to comprehend the reporting requirements, prepare its systems and workers, and establish the treatments needed for developing the needed reports, and a typical 31 minutes per month for ongoing reporting. 2 GSA does not supply adequate detail to evaluate how these estimates are flawed, however practically every informed celebration who has weighed in on these price quotes thinks they are inaccurate.

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Reg. 11625.

Otherwise, the professional will risk a claims of scams under the False Claims Act, as has been the case with basically every other form of rate or expense reports sent by a contractor to the government. Significantly for this hearing, little services will bear the largest part of this burden-- GSA estimated that out of 15,738 suppliers holding contracts that would be subject to this Guideline, 12,590 are small companies (GSA Search Engine Ranker Services).

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Reg. 11625. III. The Anticipated Benefit is Improperly Defined, and Not --------------------------------------------------------------------------- Likely to be Recognized GSA prepares for that the transactional data will "improve GSA's capability to conduct meaningful rate analysis and more effectively and effectively validate fair and affordable prices"on its contracts and will allow federal government purchasers "to compare prices prior to placing orders." 8 GSA likewise acknowledges a point really essential to market-- that price paid is only of numerous "information points"in figuring out the finest value to the government. 9 Similarly essential are other considerations, "such as overall expense, preferred performance levels, delivery schedule, special terms and conditions, time considerations, and client complete satisfaction." 10 We can also add client service, item support services, service warranty, and other terms to this list (GSA SER).

According to GSA's own analysis, this burden enforced on contractors will supply the government with only one of the required info points-- transactional rate-- without any methods to obtain the other details points necessary to evaluate price. Without access to, and factor to consider of, this other essential info, the price information is of little value at finest and can be really deceptive at worst.

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In my view, the inability of the Rule to catch these other non-price elements might be especially damaging to little businesses. Small companies typically operate as value-added resellers or otherwise distinguish themselves in the competitive market based upon the value they include to a transaction, such as client and item service capability, that is not captured by transaction cost.

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