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Contractors that use and depend on the other important terms and conditions will be unable to contend and will eventually leave the federal government market. In my view, small companies are most vulnerable to this consequence due to the fact that they often find it more tough to contend simply on price. GSA Search Engine Ranker Services. This is not an unfounded concern.

The Guideline does not explain the treatments that will be used to obtain access to, disclose, or secure the data sent by professionals. In the lack of any description of the security of this extremely delicate information, industry is concerned that it will make its way into the hands of competitors either through Flexibility of Information Act requests, disclosure during negotiations, breach of GSA's systems, or --------------------------------------------------------------------------- other unintentional disclosures.

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Under the proposal GSA would extend the brand-new data reporting requirements to other schedules if the pilot results demonstrate that it is an "efficient pricing model."We share the agency's objective of providing items and services at the very best value possible for federal government clients and the American individuals. However, we have significant issues whether analysis of item level prices could be effectively used to complex engineered systems without jeopardizing the very best worth proposition.

In pursuit of that objective of ensuring that quality items are supplied at reasonable rates, the PRC system currently in location does acknowledge the differences between the complex systems offered by different suppliers due to the fact that the comparison is to commercial consumers of the same supplier. Because of those distinctions in between the items and systems provided by various suppliers, contrasts between suppliers typically result in an "applies to oranges"contrast.



How GSA will use the information gathered is also a key concern. In the proposal GSA mentions that the data will help personnel in conducting horizontal cost comparisons, and that assessment of rates paid details must be within the context of seeking to acquire finest worth for the taxpayer. It is meant to be "one details point"amongst others for consideration by the contracting officer, consisting of overall cost, efficiency level, shipment schedule, distinct terms, and so on

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We are worried whether the information would be examined correctly in light of current practices. Even more, FSS professionals frequently provide "area prices"and special discounts to federal consumers, maybe due to geographic location, ease of service or volume, and under the PRC they have the capability to discuss such discounts.

The transactional data needed to be reported under the proposition likewise appears to consist of a great offer of proprietary rate info. In implementing any reporting requirement, GSA should provide a safe and secure website for transmission and storage of the data and make sure contracting officers are trained and geared up to handle their obligations to safeguard the information.

These extra requirements could easily cost small companies 10s of countless dollars depending upon the existing systems in location. Further, replacing the PRC's tracking consumer requirement with transactional information reporting will not relieve schedule contract holders from the burden of preserving industrial sales format information, which under the proposed rule could be needed by GSA at any time during the life of the contract (GSA SER Software).

businesses and taxpayers alike. We stand prepared to address any additional questions or supply any more details you might require. Thank you. [all]

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