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Published Aug 31, 21
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I hope the GSA will either abandon this technique and start over or seriously remodel the rule prior to it becomes final. This is a concern the Subcommittee will be monitoring and will continue to keep an eye on, and we eagerly anticipate having another chance to consult with you if that is necessary.

Without objection, so bought. And thank you once again. Intro Mr. Chairman and Members of the Committee, my name is Sheila Armstrong.

The Proposed Rule does not apply to VA --------------------------------------------------------------------------- FSS contracts in the pilot program. GSA grossly underestimates both application expenses and compliance costs of transactional data reporting.

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Third, it does not appear that GSA is certain how it will utilize the voluminous quantity of information that it seeks to collect under the Proposed Guideline, however the potential for down prices pressure that likely will result from transactional information reporting may have an out of proportion result on small services who seldom win a "race to the bottom" on rates.

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This information also is safeguarded from disclosure under the Trade Tricks Act. Select Congress Regarding the Proposed Transactional Data Rule A. Approximated Implementation and Reporting Costs of the Transactional Data Rule GSA estimates that the public reporting burden for its professionals to initially set up systems for transactional data reporting at six hours. 3 GSA estimates that the regular monthly burden thereafter will balance 4 approximately 0.

e - GSA Search Engine Ranker. sales) and assumes month-to-month reporting concern increases with vendor sales based upon the circulation of sales and responsibilities within FSS agreements and non-FSS contracts." 6 What GSA enables no time at all for is system enhancements that may be required must GSA elect to change the fields of information to be reported as it would can do upon 60 days notification under the Proposed Rule. 7 In addition, these price quotes of 6 hours for initial set-up and 31 minutes per month for continuous reporting are grossly ignored.

Reg. 11625. 3 Id. 4 GSA approximates a variety of two minutes (for specialists with $0 in sales) and 4 hours (for specialists with higher than $50 million in sales). See id. 5 Id. 6 Id. 7 Id. at 11628. 1. Initial Set-Up Likely Will Far Surpass Six --------------------------------------------------------------------------- Hours GSA estimates that its specialists will invest roughly 6 hours to set up its systems to create the regular monthly report needed by the Transactional Data Guideline. 8 This six-hour quote includes the time that GSA quotes will be required for examining directions, searching existing databases and other sources of information, and event and evaluating the collected details. 9 This estimate likewise includes the effort that GSA expects contractors will be needed to make to institute changes to specialist training, compliance systems, settlements, and audit preparation-- and most likely consists of the time and cost needed to customize data- gathering, reporting, and information-technology (IT) systems to precisely and effectively report the information required by the Proposed Guideline. 10 GSA's own Inspector General's workplace acknowledges that specialists likely will invest even more than six hours to establish service systems for transactional information reporting. 11 As the GSA Office of Inspector General notes in its remarks to the Proposed Rule: --------------------------------------------------------------------------- 8 Id.

Provided this, we question whether GSA's price quote of 6 hours per professional to configure their --------------------------------------------------------------------------- systems for reporting is accurate - GSA SER Services. 12 12 Id. This six hour estimate must assume that all information fields live in the very same IT system which the report can be set up by one individual without consultation with others inside or outside the business.

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In most cases, the systems that house the various fields GSA is asking for in its month-to-month report are not set as much as interact with one another. Accordingly, some contractors will need to manually compile the info needed for transactional information reporting, or might need to upgrade their IT systems in --------------------------------------------------------------------------- order to comply (GSA SER Software).

For some contractors, especially small companies, setting up systems to catch and report transactional data might include consultation with specialists outside the company at hourly rates thereby increasing the expenses to the professional. These estimated expenses are not factored into GSA's six hour quote for established. 13 --------------------------------------------------------------------------- 13 As kept in mind in the ABA's Comments to the Transactional Data Guideline: The Section recommends that the hours required will in truth be much higher.

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Many contractors might require considerable changes or upgrades to business systems in order to provide the data looked for by GSA in a kind that will allow for significant and accurate pricing comparison as intended. The fields required by GSA for transactional-data reporting may not reside in the exact same IT system; few accounting systems consist of both producer part number and professional part number in the same system when those part numbers vary.

g., products management) to satisfy the requirements of the Proposed Rule. These and other needed modifications would need coordination among functions such as the specialists' IT departments and change management groups as well as responsible executives. The time needed just to search for, extract, evaluation, and test such data, and execute system adjustments, will well exceed six hours.

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The approximated 31 minutes per month does not include any time enabled for ongoing upkeep of information, including but not limited to changes by GSA to the data fields required as permitted by the Proposed Guideline. 14 Given the unidentified implications on a professional ought to it offer data to GSA that is inaccurate or insufficient, professionals will need to review the transactional data prior to submission which might take hours relying on the size of the agreement.

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--------------------------------------------------------------------------- 14 80 Fed. Reg. 11628. B. GSA's Proposed Growth of Commercial Sales --------------------------------------------------------------------------- Practice Disclosure Requirements is Unduly Troublesome All GSA professionals should prepare and send CSPs prior to award and at specific crucial times during performance of a GSA contract. When a specialist looks for to increase costs or include items to the agreement GSA requires either new CSPs, or a declaration from the professional that the CSPs have actually not altered considering that the time they were last submitted.

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Due to the prospective monetary risks produced by inaccurate CSP disclosures, professionals should spend considerable time reviewing sales information and preparing existing, accurate and total CSPs when they are needed to do so (GSA Search Engine Ranker). Even a statement that the CSPs have actually not changed requires substantial evaluation of transactional sales information to validate that this statement is right at the time that it is made.

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