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Federal Marketplace Industry Day – Commercial Platforms Panel

Federal Marketplace Industry Day – Commercial Platforms Panel


MS. PHILCOX: Hello, everyone. Welcome back. Hope you enjoyed lunch. And it
looks like there — it looks like there is a few
new faces in the audience. We may have swapped
some out, had some leave, and had some join us
for this afternoon. So thank you for being here. We’ve got a large contingent online as well. So we’re back to talk about the
commercial platforms and give everyone a Phase II
update. So without further ado, we have an
esteemed panel with us here today of mostly GSA
folks who can help explain what commercial platforms are and how we’re planning to go
about addressing the requirement that we got. And here to moderate this panel for us
is our own Chris Averill. He is with the Office
of Congressional and Intergovernmental Affairs at
GSA, and he will moderate the session for us. MR. AVERILL: Thank you, Crystal. Good afternoon, everyone. We’re pleased that
you’re here. Thanks for sticking it out through the lunch break and coming back, and thanks
to everybody who is new for joining. We are going to have a wonderful
discussion this afternoon about the commercial platforms initiative. And so we’ll start with
all of our panelists, giving some brief updates from their perspectives, and then there will
be time for Q&A, at which point I would ask
everybody to kindly limit their questions to one,
so we can get through as many as possible. And
if there’s additional time, we’ll consider others. So for the afternoon, the team is here
on stage to focus on providing a Phase II update
on the initiative. That will include a review of
research findings to date, some insights on the
road ahead. That includes some extensive
discussion around the draft program documents that GSA and OMB recently released on FedBizOpps
for feedback on that proof of concept. So there are some links to that
information that are on the Commercial Platforms Interact Group. If you don’t have the link to
that, we will make sure to provide it by the end
of the afternoon, so that everybody can view the
documents in their entirety and provide comments in the recommended timeframe. And so without further ado, let me
introduce the folks that are on the stage. To my immediate left is Matthew Blum. He is the Associate Administrator for OMB’s
Office of Federal Procurement Policy. To his
left is Laura Stanton. She is GSA’s Deputy
Assistant Commissioner for the ITC Category Management. She is also the executive sponsor
for the commercial platforms effort. Mark Lee to — is down on the end. I’m a little out of order here, apologize. Assistant Commissioner for GSA’s Federal
Acquisition Service, Office of Policy and Compliance. And, finally, we have Jeff Koses. He is GSA’s Senior Procurement Executive in
our Office of Governmentwide Policy. And so with that, I will turn it over to Matthew, who will be our first speaker. MR. BLUM: Chris, thanks very much. As I said, I think this is now our third public
meeting on the commercial online marketplaces, so
I feel like we are almost like a family now. And
I guess we have to give names to the — to our —
to keep track of these events, and maybe this could be the home for the holidays, or maybe
not. We’ll see. (Laughter.) MR. BLUM: But as everyone knows by
now, the President’s management agenda is intended to drive integrated bold change in
how the government delivers its mission. And earlier this morning you heard a
lot about GSA’s vision for modernization of the
federal marketplace. And as the Office of
Federal Procurement Policy thinks about what modernization looks like across the government
to build on GSA’s ideas, we were giving careful
consideration to the role of pilots and testing as a way to help accelerate incremental transformation to our acquisition processes. Last time I think I started with a
history lesson on open market buys. I won’t do a
long history lesson today, but suffice it to say
that when OSTP was first created in 1974, Congress had the good sense to include as
one of our core functions the encouragement of pilots
and proofs of concept. And over the years we have seen some
significant pilots that have had an important and
positive impact on our system. One easy one that
comes to mind was the migration of the old Commerce Business Daily to federal business
opportunities. And I’m old enough to remember when we
had the Commerce Business Daily, and I thought it
was going to be intractable and we’d never be
able to move off of the paper copies of that and
to the — to federal business opportunities. So
that had a lot of goodness that actually started with pilot authority that was given to us
by Congress in the Federal Acquisition Streamlining Act. But by and large, I think it is
probably fair to say — and I think my colleagues would probably agree — that, you know, while
we do have good examples of pilots and
demonstrations, by and large, they have been relatively small in comparison to the
opportunities that regularly present themselves. Pilots and proofs of concept have a
number of important benefits that you know well. First, they help us build the evidence to
support further investment, and they allow us to make
course corrections based on the evidence that we
have. And if done correctly, they allow us to
disrupt the environment in a manageable way. So what do I mean by “manageable
disruption”? And you know all of this, too, five
kind of points here. One is, you know, talk to stakeholders
to shape the proof of concept in the most thoughtful way possible considering impact
and feasibility. Second, start small. Test, evaluate,
retest, before you scale and institutionalize. Third, collect meaningful data to
enable smart course corrections. Four, understand risk. Go in eyes
wide open, and in the case — and this has come
up in our prior conversations, and I know a
little bit this morning, making sure we understand the challenges faced when buying,
you know, from a source — from sources that haven’t
necessarily been fully prescreened. And, fifth, rationalize results. And
here, you know, if something works well for COTS,
you know, through this process, we need to figure
out, if it makes sense to apply in other spaces, we need to harmonize our activities to the
nature of what we’re buying — COTS — and not
necessarily to the vehicle that is being used, a
point that you all have made clear to us. Well, I’m guessing most of you here
have had a chance to at least peek at some of the
materials that GSA has shared in advance of this meeting, and you will obviously see that we
are positioning ourselves to evaluate the
opportunities posed by the commercial market line
— sorry, commercial online marketplaces by starting with a proof of concept and following
the principles that I just described — talking to stakeholders, starting small, collecting
data, understanding risks. And let me put a pin for a minute in
the first point of stakeholder engagement. In a
moment, Laura, Jeff, and Mark are going to spend
some time helping to digest the vision for this
proof of concept as presented in the materials that have been shared with you. And as you listen to them, I hope it
isn’t lost on you that your input that you have
provided, whether it’s in response to some of the
RFIs or in one-on-one meetings, if you have been
part of them, that they are helping to shape features of our internal implementation efforts. And I do think this is important
because your time is valuable, and we want you to understand, as we have these sessions and
move forward, how we are thinking about what you’re
telling us. And let me give you three relatively
simple examples, but I think they set the framework for the discussion today. So Example 1 is the scope of the proof
of concept. As you know by the four corners of
the law, this initiative is limited to the extent
it focuses just on COTS and purchases below the
SAT. And I think when the law was first enacted,
it probably is fair to say that we were thinking, okay, you know, the SAT is pretty manageable. It’s a relatively small percentage of our
total dollars. You know, we’ll work towards doing
activities and transactions that go up to the
SAT. Well, the feedback that you provided
this past summer to the RFIs that GSA issued reinforced the potential complexity we face
even in the SAT space and sorting out the roles
and responsibilities between four parties, right? This is a true quadratic equation — GSA,
the platform providers, sellers, the ordering
agency. And for the many compliance
requirements that apply even below the SAT, this
is — this, you know, seems somewhat daunting until you think through it and work through
it. So this has played a big role in focusing
our initial plans for the pilot on activity under
the micropurchase threshold. Example 2, rules of the road. At the
last town hall, I discussed our vision of how
online marketplaces might be thought of as an
opportunity to modernize the three phone calls rule of the 1980s and 1990s where buyers could
go to their rolodexes, identify three vendors,
make calls, and basically select a winner. And for those of you that have been
around for a while, you will remember that that
was probably the most significant source of flexibility — I see some nodding heads — that
existed in the 1980s and early ’90s. And when we were negotiating the
Federal Acquisition Streamlining Act with Congress, many of our senior procurement
executives were like, please, let’s raise thresholds and focus on that relief. While it’s interesting, by the way, as
an aside, after I did that little review of history, some folks came up from the last
event, and there were some millennials that were
like, “Oh, we really loved this history lesson. Thank
you so much. What’s a rolodex?” (Laughter.) MR. BLUM: Translation: you are so
old. (Laughter.) MR. BLUM: But then, also, some of the
folks that are my contemporaries, you know, said,
“Not so fast,” weren’t quite as enamored with my
storytelling and said that, you know, “Let’s not
talk so quickly through this. And, remember,
there is an important difference between what we’re talking about today and the three phone
calls.” And that being that that authority is —
which is in the FAR was provided to warranted contracting officers that had a fair amount
of training in our system and rules. So as you move forward, we need to
make sure that if we’re going to place more attention on the use of marketplaces and cards
and those current cardholders, we need to remember that the rules that exist in the
FAR for micropurchases may need a little bit of tweaking
to reflect the good thinking that our warranted contracting officers were doing with three
phone calls. And you will see in the handout
materials that we have developed — or I should say GSA has developed a set of ordering
procedures that we are putting out for your comment and thought well in advance of when
this will take effect, so that you can work and
offer your thoughts back to us as we try to strike
that right balance between efficiency and smart
buying. Example 3, rationalizing our tools. So many are asking if we are thinking about
the relationship of this program as it relates
to category management as well as the schedules
and other existing vehicles that people use today
for buying small dollar — making their small
dollar purchases. You’re going to be hearing a lot of
discussion on the role of data, which is probably the single most important value add that GSA
can offer initially in this program. Why do I say
that? Well, it’s going to help our buyers, and
it’s going to help our managers make rational decisions as to which tool makes the best
sense in any given situation, which they can’t easily
do today. And by doing that, it preserved the
toolbox approach that we have always — and I
think need to continue to embrace — to give our
buyers as many options as possible while minimizing unintended consequences. These three features start with
micropurchase, have online ordering procedures ready to go at the outset, and emphasizing
our data analysis were all honed based on the
many conversations that we have had with you. And I,
again, applaud GSA for this prudent market research. At the same time, and my last point,
is I also applaud them for starting to nail down
a timeline for launching this proof of concept, which Laura and team are going to talk at
this as well today. So why am I emphasizing this latter
point about, you know, we need to move forward? Well, many of you have asked us what we’re
doing about agencies that are starting to experiment
with marketplace providers on their own. And to
be honest, some of these questions have come to
us kind of in a whisper, and some of them have
come, you know, with you using your outside voices in blogs and in other kind of very
public statements, which is very fair. This is a
legitimate question to ask. And as GSA and OFPP, one thing we
share in common is we are responsible by statute for thinking through whole of government issues. But the truth of the matter is, it isn’t bad
behavior on the part of our agency colleagues who
want to continually look for new and better ways
to serve their customers, right? This is the most basic definition of
“innovation” and the strongest antidote to insanity where we do the same thing every
day and expect better results. And as I said at the
outset, we need to do more piloting and experimenting. So in some levels, you know, we
are in kind of a weird situation if we don’t move
forward, because we can’t then criticize our agency colleagues for wanting to take advantage
of these technologies and figure out how they can
buy faster and smarter. That said, we don’t want Balkanization
where a whole of government sandbox can be stood
up to do this testing. So while we must continue
to exercise prudence, and I can — I am confident that my colleagues and I know our office are
going to do that, the sooner that GSA can stand up a smart proof of concept and get that off
the ground I think the better off we are ultimately
going to be in rationalizing our testing, our
understanding, and our ultimate scoping of this
opportunity for the longer term. So with that, I am now going to turn
to Laura, Jeff, and Mark, who are going to do
somewhat of a deeper diver on some of the details
of this proof of concept. MS. STANTON: Great. Thank you,
Matthew. And thank you, everybody, for being
here today. We did get a little bit of an
upgrade from the GSA auditorium in order to accommodate all of you. But today is important for a number of
reasons, not only because we’ve had a chance to
dig deep into the federal marketplace based on
what was — what the GSA administrator had an
opportunity to address this morning, the schedules modernization, and now going into
another aspect of the federal marketplace, the
commercial platforms initiative. And I appreciate Matthew really
highlighting three key elements of this. First
of all, the proof of concept and the importance of pilots. The second is the whole of
government, and the third is the data, because all three of those have been recurring themes
that we have been hearing that he quickly identified and pulled out in the way that
Matthew does. I also do feel like — a little bit
like I have — you know, that it has become sort
of a sibling group with the four of us spending this much time together over the past year,
and all of you seeing us together, too. But today is also the one-year
anniversary since the FY18 National Defense Authorization Act was signed that brought
Section 846 into law. And during that one year, we have
been — we have spent a considerable amount of
time listening to you to learn more and to take
the lessons that Matthew — that Matthew identified and then all go deeper into to
make the decision — actually, to put forward the
ideas. I won’t even call them decisions yet,
because we want to hear your feedback on them before they begin decisions, but to begin
to identify the path forward. That was built off of the listening
session that we held back in January where, if
you remember, the only thing that we said was to
actually ask a whole series of questions. In
June of 2018, we sat down again and went through another listening session where we began to
also share some of the initial market research
and some of the report information that we had
completed back in March. And then, finally, today we are
finally ready to share with you and highlight some of the key thoughts and the path forward
that will move us into the proof of concept for
the whole of government the way that Mathew described. And during this time, what you’ll hear
from us is — I think a number of you, I hope, will recognize the feedback that you gave
us and understand how we took that, we learned from
it, and that we began to use that to shape our
progress forward. But before I get into sort of what
that is, let’s just take a step back and talk a
little bit about Section 846, what it — and for
those of you who may not be as familiar, some of
you have been along the path every step of the
way with this, and others might just be coming into this today. First of all, GSA is charged with
establishing multiple contracts for electronic commerce portal providers. We have to consider
portals that are widely used in the private sector and that provide features such as supplier
and product reviews, invoicing payments, and customer service. The program would be implemented in
phases over several years, allowing the government to consider such issues as data
security, supply chain risks, and cybersecurity threats. That was originally called out, that we
wanted to do a phased implementation to allow us
time to identify and work through some of these
issues. And then, finally, GSA has asked to
accept portal provider terms and conditions, where possible, but should judicious in asking
for exemptions from existing rules and regulations. Put that into plain English: we
are asked to accept all commercial terms and conditions at the same time that we make no
changes to our — to the existing procurement laws and regulations. For those of you who are familiar with
both worlds, you’re aware of what the — what challenge that presents to us, and we have
worked very hard to sort of thread that needle in
the most useful way possible. Then, a few months ago, the FY19 NDAA
was signed, and the commercial platform’s e-
commerce surfaced once again with some important clarifications based on the conversations
that we had been having. GSA now has the authority to
develop the competitive procedures, and this is
both — and Jeff will address competition at a
deeper level, but this addresses both at the marketplace competition level and at the ordering
level, and the role of competition is critical to
the success of this program. The language in the FY19 NDAA
reiterated the need for multiple contracts with
multiple portals. This was a point that we heard
from all of you starting last January, as well as
that we should be looking at this as a proof of
concept, and that we need to have the buyers comparison shop as they go — as they make
their purchases. Data usage protections were
strengthened, stating that portal providers cannot use spend data for pricing, marketing,
or competitive purposes. This has been one area
where we have heard a lot — quite a bit of feedback, and we’re taking that into account
as we go forward. We know that we still need further
feedback from you in this particular area, and
you’ll see that that is called out in the RFI as
well. And in FY19 — and for 2019, the
micropurchase threshold increased to $10,000 for
Department of Defense. So having stated these items, based on
the legislation, we also share — we also have a
series of program objectives that we’re working to accomplish. The first is modernizing
commercial product buying experience. The second
is simplifying and streamlining COTS item purchases to allow agencies time to focus
on their mission-oriented acquisition. And then, finally, analyzing the COTS
item purchasing spend data to allow for better buying decisions. We held — we recently held a
customer workshop, and we are talking about the
value proposition. During that workshop, one of
the agency — we asked what the value was for —
and one of the agency representatives literally leapt out of her chair going “Data. I want the data.” And she was one of many voices in the
room emphasizing the need and the desire to be
able to get to that level of transactional data. We conducted a significant amount of
research in Phase 1, and we heard a series of —
we heard a number of key themes around maximizing the flexibility and maintaining a balance
of regulation and good public policy. We are still
trying to work through exactly the tensions with
both of those. But our Phase 1 recommendations
focused on modernizing competition requirements, given the — and which we did get as part
of the FY19 NDAA. We are currently in Phase 2 of this
effort, which calls for intensive market research. That research was used to guide the
recently released request for information and
will help us shape the contents of the March 2019
report. So we appreciate everything that
you’ve done to date and ask you to continue to
help us out with more and offer feedback. In the last year alone, we have conducted the three
industry days that I referenced already. We have
released multiple RFIs. We also have met with 75
companies for one-on-one demonstrations and discussions about what this program could
potentially do, and we have participated in numerous industry events to speak about this
initiative. So we have conducted extensive
stakeholder research on the industry side, and we
have worked across the government to understand what the critical things are for them as well. We still have more — I want to emphasize,
though, that this — we are going to continue to
have opportunities for your involvement and for
your feedback. As we begin to talk about the RFI that
was released, that is beginning to shape and form
the proof of concept that we are targeting for
the end of 2019, and that is all built on what we
have learned to date. So as we think about the proof of concept, we have a couple of goals. The first
is, let’s get something out there that the buyers
can start using, so we can figure this out. Going back to Matthew’s point, we have spent
— we have spent a lot of time learning. Let’s now do something. Let’s test
this effort and acquisition reform at large in a
controlled environment before going all in. And
then, finally, to begin to understand the potential impacts on other programs as we
begin to use real spend and begin to see that. So the proof of concept is really —
is critical, and it’s also something that if we
don’t — we need to continue to progress, so that
we have alternative and we have Section 846 in
place for the whole of government to be able to
use. As part of the RFI, we talked about
the key objectives, the same one I referenced earlier, the modernizing the commercial buying
experience, simplifying and streamlining COTS item purchasing, and analyzing the spend. So we also have — what we have done
with this RFI is we have actually put something on paper for you. As I said, we have been
listening. And after a year of listening, we
have decided that it’s time that we owe you something. So let me walk through the program
outline, the go/no-go requirements, and then ultimately the capabilities that we are looking
for. GSA intends to award multiple commercial e-
commerce portals in support of the commercial platforms initiative. Starting from the
beginning, you have told us that we need to have
multiple marketplaces. I remember — I remember
it very distinctly back in the January — we heard it loud and clear during the January
session. We planned to — we planned for the
proof of concept to permit spending up to the
limits of the micropurchase threshold, which is
today capped at $10,000 per order. Orders will
not be accepted above that, and keeping purchases below the micropurchase threshold really keeps
us very closely aligned to the commercial buying
practices. This gets back to what I mentioned
earlier on being able to sort of thread the needle on commercial versus retaining the
rules and regulations. The proof of concept will test
an e-marketplace model. The e-marketplace model
is defined as an online marketplace that connects buyers with e-marketplace providers, proprietary
products, and third party vendors’ products, or
in some case only the latter. E-marketplace providers and third
party vendors are responsible for fulfilling orders for their respective products with
some exceptions where the e-marketplace providers
may complete order fulfillment for an extra fee. GSA’s intent is to start with a lightweight
model that is different than what is commonly used
today in the government e-commerce portals. The other thing we learned is that
e-commerce — e-marketplaces are relatively new in the business-to-business space. We may be
familiar and use them extensively in our personal lives, but many of the B2B capabilities that
we are asking for and that we are looking for
are relatively new and often just under development. And so we want to be able to grow with the
providers as they mature their offerings as they
go forward. On the go/no-go requirements that we
are looking for, we really — and these are based
on the stakeholder research, we are really going
to be looking at what would not reflect commercial practice, and the proof of concept
is really intended to address a smaller segment
of the federal markets to allow us to test these
acquisition reform concepts on a smaller scale. And then, finally, on the capabilities
that we are looking for, we are looking for the
in-depth product content and product reviews to
aid the market research. We are looking for
dynamic pricing and price comparisons to ensure competitive pricing available to the federal buyers. We are looking for information and order
status, and delivery tracking is part of the post-purchase process, and a robust workflow
process between the work — between the purchasers and the approvers. With all of these attributes combined,
we feel that the buyer will really experience a
more robust and a modernized COTS buying experience than we have today. We want to be
able to offer up the maximum amount of research for the buyers to have access to, and to be
able to acknowledge and identify the cost savings
across the commercial items. And we want to be able to leverage
commercial practices by offering that — the workflow processes and detailed visibility
into the order status. There is more information on all of
these items that I discussed, but this gives you
a flavor as to our initial thoughts and where we
want to take this. So I’m going to — that’s very much the fact-based outline, and I’m going to be
passing it over to Jeff to talk about really how
GSA is using this to balance the policy objectives. Thank you, Jeff. MR. KOSES: Thank you, Laura. Matthew
really gave you a terrific overview sense of
three of the key items to be thinking about and
set the context beautifully. Laura then married
up — those of you who have been following this
initiative through every twist and turn for the
last year, to those of you who are new to the
initiative, gave you the overall sense of where
this is going, when it’s going, and some of the
key things. I wanted to take you now into some of
the policy reasons, some of GSA’s thought process, as we have been laying out our initial
set of thoughts. And I’m specifically saying
initial set of thoughts, not decisions, because we see this as a continuation of a dialogue
which has been underway for the last year. So as we’re going through these
thoughts, we have not locked down, yes, this is
the exact answer, but I think it will be helpful if we go through how we’re thinking, approaching
these issues, and why we have put out the concepts the way that we have. To organize this part of our
conversation, I think it is helpful if for the
next few moments we think in terms of five major
buckets to kind of walk through, talk through, and understand the policy issues that are
at play. These five that I’m going to talk
about are, first, competition, what that means, where we’re going with it; second, customer
satisfaction and the importance of that in this
whole effort in maintaining the unity of government that Matthew spoke of. I want to talk about creating the
right incentives, the right incentives for all of
the different parties who are part of this. I
want to talk about understanding and managing risk, and then I want to talk about a broad
category that I’m calling savings and public policy. This is an area where I expect many of
you are going to have a lot of questions that we
can spend some time talking through. So as you’ve already heard, we’re
looking at operating at the micropurchase level. So let me then turn to competition first as
the first of these buckets to start walking, talking,
and thinking through. From the earliest moments that GSA
learned of Congress’ interest in this initiative, we started stressing the importance of a
competitive procedure. That was our very first
set of comments on the first draft is, no, it’s a
mistake to go with an idea of awarding one, that
there needs to be an award to several, and we
outlined several reasons, not the least of which
is the long-term risk to us in being dependent on
a single provider. Also, concerns about stability of the
marketplace, small business opportunity, we outlined a number of concerns on competition. We
stayed pretty consistent on that message through every twist and turn, through all of the
subsequent versions of the bill, until we actually saw the version that was enacted
into law and even the most recent set of changes. But when we are talking competition,
we’re talking competition at multiple levels, and
I think it’s really important to understand each
of these levels. One, we’re talking competition at the
contract level. In the June meeting, I spent a
few minutes talking about that. And at that
time, I told those of you who were then following along that we need to make more than one award,
that if we receive only one technically acceptable offer in, that we are going to
cancel the solicitation, we are going to take several
steps back, we are going to return to our market
research, figure out why we didn’t get better competition, and then figure out a path forward. I want to reaffirm that today. We are not looking for a proof of concept with one
provider. There needs to be multiple e-
marketplaces for this to be successful, for this
to accomplish its purpose. Second, though, we are talking
competition at the order level, and this is a
significant and fundamental shift when we think
about what a micropurchase is, how it operates, what it means. We have never had a standard of
requiring competition at the micropurchase level. We are now putting that out. That is
a significant and really impactful change. That
is a direction that would take federal government purchasing into new space, new procedures. And
the importance of that really needs to be heavily
underlined. We are also, though, talking
competition from the supplier perspective. One
more reason we thought it’s important to have multiple e-marketplaces is so that suppliers
themselves have a choice, are not forced into just one relationship. We heard that message from a number of the product vendors that
we met with over the last year. We have heard different concerns about
different business practices among the marketplaces. We heard different degrees of
comfort, different thoughts about which one best
would work for different commodity groupings, different areas of spend, and we saw it as
absolutely essential that the suppliers, that the
sellers, whatever term we want to use, have a
choice of one or several portals, whatever best
fits that business model. That brings me to the second major
bucket as we have been thinking this through. That’s the issue of customer satisfaction. I
think Laura mentioned that we had about 75 one-
on-one meetings. A lot of those were demos of
existing capabilities. We saw and heard from our
portal operators, from e-marketplaces, and from
the e-procurement solution providers. One thing that really stood out for
us, something we found tremendously impressive, was the emerging capability in the B2B
functionality. We saw a number of things that we
thought were especially valuable and impactful. I’d put some of the workflow tools at the
very top of that list. I would also include product
comparisons, ability to have a preferred vendor listing, ability to load your existing contracts
within those, the capacities for discounted pricing, a lot of really intriguing tools. That combination of elements really
led us to say, you know, when we talk about proof
of concept, where is the best place to start? That’s part of what took us to the thought
that it’s likely the e-marketplaces that make the
most sense as the first iteration to move forward
in this. That said, we also are really
interested in some of the functionality we saw
through the e-procurement systems. Our sense is
that comes at a future stage of the procurement –
– of the program. It probably doesn’t fit when we’re talking micropurchase. It certainly
doesn’t fit when we’re talking a lean start and
moving forward. But it clearly seems to be part of
this program. There is a really compelling,
intriguing vision, one that we want to learn more
about as we move deeper into it, as we move to
successive proofs of concepts, and as the effort
matures. As we’re talking about some of these
issues in and around customer satisfaction, we
recognize ease of use, compliance, good pricing, they’re all going to be key. Part of why they’re
going to be key is we’re asking a lot of a lot of
different players in this space, and it’s important — let’s recognize, what are we
asking from the different participants? Let’s start with our purchase
cardholders. We are asking them to operate very
differently than they have up until now. We are
asking them to consistently look at more than one
source. We are asking them to recognize some new brief documentation requirements. We’re asking
that they be prepared to likely face additional questions, and ask — we’re trying to build
this environment. We are specifically asking them to
move their open market spend, their true micropurchase spend, to a GSA-managed program. I
want to emphasize that we are talking a very sizeable spend that does not go through any
contract vehicle today. We are not talking the
micro — we are not talking buys under $10,000 that may have schedules. We are talking true
micropurchases, vehicles today that don’t have a
contract, and we see just tremendous value in
targeting and focusing on that segment of spend
and moving it. That’s our purchase cardholders,
though. Second, our agencies. What are we
asking of federal agencies as part of that? Well, this is about starting to bring management
to their micropurchase buys. It’s about the need
to get the visibility, to see what and how that spend is happening, and potentially to start
shifting that spend, not just shift it to the GSA
solution, but perhaps shifting that to some of
the mandatory sources. Today, for instance, we have no
visibility on the AbilityOne spend in this space. We have no visibility on the federal prison
industry spend. Candidly, we just don’t have the
insights into what happens in micropurchase spend
to date. Laura told you there is a huge thirst
for data among the agencies. There is a big
desire on our part to share that data with the
agencies to have them use that to start changing behavior. That imposes yet another burden,
another requirement, on the federal agencies. We are now talking an extensive effort
at retraining hundreds of thousands of P- cardholders over time, certainly not at this
stage of the program. At this stage, we are
talking a proof of concept. Long term, though,
this is all about agencies retaining cardholders. Third audience, what are we asking of
our suppliers? Certainly, better pricing. When
do we not ask for better pricing, right? Of
course we want better pricing. More than that,
we are looking for you to be able to compare marketplaces, to identify which is the right
channel for you to sell, and sometimes this is
saying, “Let’s establish a new channel, let’s come into a managed program” in doing business
across the government marketplaces. We’re certainly asking for a lot of
workflow functionality. We’ll go through several
of these, I suspect, both in the statements and
public policy comments and in your questions. But EPLS checks, for example, we would love
to have some assurance that we are not buying
from excluded parties and to have the proof of
that. We are looking for the marketplaces to
be able to display things such as environmental attributes, a whole host of data elements
that in different ways federal agencies can provide,
but we don’t have today centralized, invisible, across micropurchase spend. In marketplaces, we’re asking for
extensive data collection and reporting-type requirements. So if we’re going to be asking so
much more of the buyer, of the agency, of the
supplier, of the marketplace, we need a better overall experience. We need to have the savings;
we need to have the value. That brings me to my third major
bucket as we’re thinking this through. That’s
how do we create the right incentives? So let’s
run through those same four players in this. The
purchase cardholders — well, for them, the buying experience, it has to be fast, it has
to be easy. They have to have confidence that they
are getting good pricing; confidence they will be
in compliance with the rules; frankly, confidence they are not going to be criticized for using
this. One of the GSA initiatives that we’re
working I’m calling taking the fear out of buying. It’s part of our initiative. It’s part of our focus across the agency this year. As we’re talking our purchase
cardholders, one of the values that agencies have
communicated is their folks are so uncomfortable making a buying decision. There is a lot of
value for us if we can free that fear up from our
purchase cardholders, make them feel confident that they are not going to be attacked for
making a decision. For federal agencies, what is the
incentive? It is freeing up contracting officers
to do more complex buys, to focus on high dollar
levels. As Matthew told you, that’s hardly a new
idea. I suspect we can probably trace that back
decades as we’re trying to say, where do we want
our contracting officers to spend their time? And I’d suggest it’s probably not
buying COTS products when there are established prices. It probably is in a whole host of
contract administration and oversight activities. It’s about giving the agencies the data to
direct the spend into more appropriate channels. We heard really great interest in
specialty markets, everything from a first responder market to various types of technical
equipment. And we heard lots of interest about
supply chain and different supply chain concerns, something that we will return to. For the suppliers, this is all about
offering new access to federal opportunities. It’s about addressing the concerns that they
have with what data is out there, how is it going
to be used. It’s about giving them a choice. For the e-marketplaces, well, clearly,
we need the ability to drive traffic and make this a worthwhile investment. Laura talked a little bit about the
direction that we have from Congress, which basically — stick as close to the commercial
practice as you can. Well, we understand that,
and we think there is great room for us to leverage what the marketplaces already have
developed and are developing. We are not talking
any fundamental change to the business model. We see a whole lot in the workflow
tools, in the account structure, in what is made
visible to different buyers, that we think comports beautifully to the program attributes
as we are currently envisioning them. So four different audiences, each of
whom need something very specific. We have to
give all of them the right incentives. At the
same time, I have already mentioned agency concerns with supply chain. That takes me into
number four. We have to know — we have to
understand the risk. One of the pieces in the legislation
told GSA, give a lot of thought to IT and healthcare items; think about whether or not
they should be bought through this type of portal. And we have heard a lot of different views
on that. At this point, the program document,
as you see, does not limit product categories. So why did we get there? How did we get there? Well, as I say, we went back — we looked carefully at the legislation, at what it said,
and it very much said, “GSA, think about this.” It didn’t say include it; it didn’t say exclude
it. It said, “GSA, study this, assess it, come
to a reasoned conclusion.” We then met with a number of the
industry associations, both in the IT space and
in the healthcare space, and we specifically explored and tried to understand their supply
chain concerns. What we walked away with, our
understanding is there is always going to be a
level of risk, and that level of risk goes up as
the size of the order goes up, as the type of
equipment you’re talking about goes up, as the —
as we start to enlist services, as other pieces start getting added to that supply chain. So we’re starting at the
micropurchase. We think that starts us at a
pretty low-risk environment. We also talked to a
number of agencies, and in talking to the agencies they each seemed to have very different ideas on what is and what is not an acceptable
risk, and where should products be limited or not
limited. Our understanding, having seen a host
of demos, is through account setup tools, through
user profiles, the marketplaces can manage that,
can let agencies establish the limits that work
based on their mission, their view, their understanding, in a fast emerging area. We heard this morning some comments
about how supply chain is likely to be a major focus of the next several years. We think it’s
early to be making decisions. We don’t think
this is the moment when we should be establishing a buy and don’t buy list across government. But
we do think it is the right time to start giving
agencies the tools to make some decisions. Point five or bucket five, savings and
public policy. In this area, we heard a whole
big collection of issues from, will there actually be savings, trade issues, AbilityOne
issues, excluded parties, a whole litany of issues well worth talking about. So let’s start with maybe one of the
more fundamental questions. Will there be
savings? Well, what do the advocates say? The
advocates tell us that there is going to be big
cost reductions, reduce administrative costs for
agencies in completing their buys. They tell us
that there will be reduced compliance costs on
industry. They tell us that there is going to be
easier access to competition, that there will be
more firms coming in looking to sell to us. They
will tell us that there is the ability to negotiate B2B pricing or, better, they will
tell us that we can use the data to better manage
our buying behavior, and that will result in savings. What do the critics say? Well, the
critics say that the schedules already have really good pricing, and let me just stop
and enjoy that point, if you don’t mind, for just
a moment. (Laughter.) MR. KOSES: I can’t tell you how many
Hill briefings, how many FAR Council briefings, how many agency conversations, how many seminars,
I have stood up and defended and talked about why
these schedules have good pricing. So, yeah, I’m
enjoying our new fans of schedule pricing. That’s awesome. (Laughter.) MR. KOSES: But, again, we are not
actually targeting the buys going through schedule — we think there is a vast and
substantial market of open market — true open
market micropurchases that is out there. Critics also point to things such as
the recent Navy postgraduate study. Other
current examples, some of the work that the coalition has done and released just this
week. They pointed to the fees that are charged
by the marketplaces and say, you know, all of these
things, they are going to push your prices up. There are savings that are going to be eaten
up in marketplace fees. So who is right, you know? Let me
suggest the only fair answer is today, we don’t
know. We have two theories of the case. We have
some pretty interesting arguments on both sides. We have no responsible data. We don’t know, are
there or are there not savings? What do we know? We know Congress gave us the authority to
run with the program. We know Congress’ sense is
that there is the potential for significant savings for streamlining for time savings. So as we think this through, that is
part of how we came up with the idea when we
launch the proof of concept, we should launch it
at the micropurchase threshold. Could we have
launched it at a higher dollar threshold? Absolutely. We had the legal authority to go up
to the simplified acquisition threshold, up to
$250,000. Matthew, I think you mentioned the
word “prudent” in the decisions a few minutes ago. So where do we think it was prudent to
start an experiment; to run with a proof of concept; to say, you know, there may be great
savings, or we may be paying more; this may work
and generate all kinds of time savings efficiencies; it may not. We thought, okay, let’s strike the
right balance. Let’s run — we have a culture,
we have an opening, we have a time when we can
experiment, when we can try new things in the
applicant environment. We don’t always have that
opening. There are times it’s very hard to
innovate and try new things. We have got the opening. We want to
explore it, and we think that the right place to
do that is at the micropurchase threshold. It
lets us test the theory of the case. It lets us
gather data. It lets us analyze the data. It
lets us prove which of the two savings sides are
right, the advocates or the doubters. If we see the benefits emerging, if we
see cost savings, if we see other improvements, then we can expand and grow the program and
move to higher dollar values, more proofs of concept. If not, we know that we’ve pursued a benefit
that didn’t work out, figure out why not. Do we
retrench the program? Do we revise it? They say,
“No, this wasn’t a way to generate savings.” Thus, data is really key to where we
go, but there’s lots of other aspects of public policy besides the savings pace. Identification
we think is a critical component. Let me return
to AbilityOne. It was mentioned a couple of
times. We’re looking for assurance that
AbilityOne items actually are included and are
being purchased. Today we don’t have that
assurance at the micropurchase threshold. We
don’t have the data. We don’t have the
visibility. Our understanding is by providing a
feed of ETS items that that can be made visible to the buyers in lots of different ways, and
the buyers can then make the right decisions. Small business — we’re looking for
ways to promote small business through the program, and our thought is that small businesses who choose to will be able to register as
such through SAM, and that information can then
port over to the marketplaces to be visible — any
socioeconomic information — for the buyer to
make a decision. It may not happen day one, it
may not happen year one, but that’s a really intriguing and new opportunity for the small
business space. We’d like to have some real assurance
that we are actually preventing purchasing from
excluded parties, and believe that by providing the feed from SAM, the excluded part of the
listing, the marketplaces can implement some of
the appropriate controls, so we have that assurance. We also think there is great value in
displaying environmental attributes and, again, believe there is a data source from agencies
on a host of those where we can put the information
in front of the buyers. Trade issues. Certainly, an area that
we have thought a lot about and considered. We’ve talked about, should we establish a
more restrictive policy? But we concluded at this
point it makes more sense to align with micropurchasing procedures. Do we want to make
it hard for people to use a government-wide program and instead create 50,000 different
variations with every agency setting up its own
program? No. That doesn’t make a lot of sense. Bigger picture, we see this as a huge
deregulatory opening. We have been able to have
some very good conversations on the importance, on the value, of deregulatory actions. This
year’s National Defense Authorization Act used
our GSA draft in trying to adopt a regulatory rollback provision, letting the FAR Council
go back and look at the last couple of decades
of new regulations and say, “Hey, does this really
need to apply to commercial items?” Give that
another thought. And, if so, explain why it
does. You know, so if we’re actively pushing
for a regulatory rollback, if we have the opportunity, if we have the opening, why would
our first action be to apply a regulatory environment not required by law, not required
by statute? We have to commit to our own belief,
our own view, on what is the right program direction? When we talk about the contracts, we
see the contracts with the e-marketplaces being
commercial item contracts, service contracts, and, as such, we put out some draft terms
and conditions. They’re a pretty limited list. The
terms and conditions are either: 1) required by
law to apply to commercial contracts; 2) required by executive order, and I think we may have
more required by executive order than we do by
law at this point; or we think that they are consistent
with the customary commercial practice. We think that based on your responses
to the earlier RFIs, based on the one-on-one conversations. But, again, we’re still in a
testing phase. We’re asking you. So if we’ve
drawn those incorrectly, if we’ve missed key points, if they are not consistent, or if
you read the law and EOs differently, let us know
that. This is the opening to make these changes
still. You know, so getting to this limited
list, it’s a pretty substantial deviation to the
FAR and the GSAR. But that is, indeed, our
thought process at this point. For suppliers, the terms and
conditions, again, are minimal — just those required by law or executive order — and
they are really minimized by treating these as
individual micropurchases, not as big umbrella contract with the suppliers. So hopefully that gives you some
insight into how we’ve been thinking, talking, exploring these issues. Let me now turn it over to Mark Lee,
FAS Assistant Commissioner for Policy and Compliance. MR. LEE: Thank you, Jeff, and I just
want to say you heard from Laura you’ve sort of got a program objective. Obviously, Jeff went
through and gave you some of our thinking around
the policy considerations. But now let’s — we’ll talk a little
bit about the opportunity that we have with commercial platforms, and I think you’re hearing
a theme that is resonating this morning, the theme of data and visibility and transparency. And so what we really do is see this as an
opportunity to take some of the open market micropurchase spend that is going on there
and bringing it under better management. So what are those opportunities? One
is the opportunity to be a smarter buyer through access to that spend data. Two, it’s really to
have some visibility and transparency into those
buys of what are we actually introducing into the
federal supply chain. And, three, we want to get
an easy experience to buy these COTS items, to
the government agencies, through simple ordering procedures. So let me take a little time and talk about spend data. GSA anticipates through the
spend data that we are going to gain new insights into spending, what is going on, particularly
around transactions that aren’t visible today. This is going to help us meet a variety of
different important government purchasing objectives, particularly in the areas of small
business, socioeconomic considerations, AbilityOne. And so in the RFI, we outlined a
number, a variety of different data elements that
GSA would be looking for e-marketplaces to provide that. GSA plans to house the data
essentially, and we plan to make it available to
the customer agencies. So what are some of the data elements
that we’re looking to obtain that should shed some light on agency spend? First is purchased
data, things like ship date, sell price, total price, agency need. Next is product data. We really want
to have good data around what products we’re actually buying, description data, information
like country of origin. We’re also looking at vendor data,
which is socioeconomic status, different things about that. In providing these data elements out
for comment, we are really trying to seek a
balance. In our market research, we saw that
different e-marketplaces have a variety of different capabilities. But we also need a
common set of data, so that we can actually aggregate the data across the program, but
also assess the impact to existing programs through
a proof of concept. In addition to standard data elements,
we are also looking at the data analytic capabilities and dashboard capabilities. So
we’re looking to gain insights at the enterprise level, what is going on within an agency,
so at the bureau levels and on down. We are looking at — for information
on frequency of purchases by agency, cost saving, shift in delivery time, and a lot of others. We
want to make purchasing history and invoices available at the buyer level. And all of this
should lead to a complete analysis of the spend
below the micropurchase threshold. We are also looking for platforms that
provide workflow, and this is really important, where agencies’ approvals — we’ll be able
to approve purchases at certain dollar thresholds
and have access and visibility and transparency into what they spend. And we heard this loud and
clearly, that there has been some hesitant in
terms of the customer agencies out there wanting to authorize purchase cardholders to go up
to 10,000. We believe the workflow capabilities may
solve some of those problems. We are also thinking about the catalog
data and how do we get access to the catalog data. So GSA is looking at some of the
capabilities of how we would do these things and
surveil some of the market — e-marketplace, so
that we are ensuring that they are meeting some things like important supply chain risk
management requirements. We will be looking at things that are
prohibited products out there, are there potential supply chain risks, and monitoring
price fluctuations. One key area that we have heard a lot
of feedback about is data rates. This has been a
concern that has been reiterated in the legislation, through our conversations with
e- marketplace providers, suppliers, other important
stakeholders. This is the area of particular
points that we have called out in our most recent
RFI, and we are actively seeking all of your thoughts and inputs on this before the March
report. In last year’s National Defense
Authorization Act for 2019, there is a section called 838. And it states, “The e-marketplace
provider shall not use government spend data for
pricing, marketing, competitive, or other purposes, any information, including any government-wide-owned data, such as purchasing
trends or spending habits related to the product from a third party supplier featured on the
platform, provided through this contract, or the
transaction of such product, except those necessary to comply with the requirements
of the contract.” And so we are trying to take a very
balanced perspective in terms of this statutory requirement. We have heard a number of different
things from e-marketplaces. We have heard that
this language is too restrictive, that some could
interpret it as the inability for that market —
e-marketplace to effectively manage the marketplace. It could limit things like the ability
to perform quality control functions or oversee performance. We have also heard that — from
e-marketplace providers that it’s not in their business model to go in and — it is in their
best interest to have third party suppliers that are accessible on their e-marketplace, and
that is an active part of their business model. We have also heard concerns from
suppliers. We have had concerns particularly
about controlled access to the federal market. They are concerned that if they have to go
through e-marketplaces to gain access to the federal market that that would limit their
capabilities. I want to reiterate that GSA is
committed to continuing competition and ensuring that suppliers have choice of e-marketplaces
to choose to sell for. If they want to participate
through the program, we are also committed to
making sure that they do have other channels to
sell to the federal marketplace. Competitive advantage. We have heard
concerns from suppliers that e-marketplace, having access, that it would give them insights
that could force them to gain a competitive advantage over those third party sellers selling
in the marketplace. GSA recognizes all of these concerns,
and we are continuing to strike a balance beam
that will leverage the benefits of e-commerce while at the same time making sure that we
are setting up a channel that is attractive and
effective for suppliers to sell to the government, and making sure that we are
increasing competition, both at the marketplace level as well as the supplier level. Now let’s turn to a topic that we
heard a little bit this morning about — federal supply chain risk. You heard Jeff talk about one
of the key things that we’re looking to do is
make sure that we understand and manage risk. And this is how we are very much looking through
the lens of this issue. Supply chain is an important
consideration for our national security. It is
an emerging challenge in federal acquisition, but
it is also an emerging challenge in the commercial world we all purchase from today. And
so we are seeing a lot of movement in federal acquisition. We will continue to see the
movement in terms of how to address supply chain
across the government. In the development of the latest RFI,
there were a number of factors that we believe reduces risk, and we’re actively seeking your
thought and impact before the March report. Here are a couple. One is the dollar
value. The proof of concept is limited to orders
below the micropurchase threshold. The
legislation actually authorizes it up to the simplified acquisition threshold. Dollar values
of the transactions, Jeff thought — our thought is that it increases as the dollar value goes
up. Two, we are actively looking to
leverage commercial supply chain risk management’s practices that exist today, and
you will see that in the RFI. Jeff and Laura
mentioned that we had over 75 one-on-one meetings, and through that, particularly with
the e-marketplaces, we got the opportunity to
get a deep dive of what type of supply chain risk management practices they already do. They do do
things like supplier value. They do worry about
issues like counterfeit items. And so in the vein of adopting
commercial practices, we should already be leveraging the supply chain risk management
practices that exist commercially. Three, applying the existing
requirements. You will see in the RFI that we’re
applying the existing supply chain requirements that apply to micropurchases. We also
anticipating that this is going to change in the
federal marketplace, so we are also asking the
really important questions of what the portal provider’s capability are to manage these
requirements over time as the government’s requirements change over time. This is an emerging area in federal
acquisition policy, and I think we all know that
there will be new requirements for the government as those policy decisions are made. So we want
to make sure that the e-marketplaces are positioned and capable of being able to meet
those requirements as they evolve out and over
time. Four, we are looking to limit the
product categories at the agency level. GSA
started with e-marketplaces’ full category —
catalog of items because it is appropriate to
government-wide supply requirements there are no
limitations that exist for micropurchases today. We are being very deliberate in that decision. We want to maintain balance incentives for
both government and industry to fully utilize this
channel versus the open market. However, we do recognize that
e-marketplaces have the ability to limit certain categories. We also recognize that there is
policy considerations at the agency level and
respect the supply chain. So we are very much
looking to the ability for the e-marketplaces to
carry the catalog that would be available to
certain agency buyers. Lastly, and one of the most important concepts that we have is the idea of
transparency. We have — we recognize that today
our purchase cardholders can go into the open market. They can go to a brick and mortar store. They can buy an item today. We have no visibility, no transparency
into that — those items. We don’t know in some
cases what we’re introducing into the federal supply chain. We see this as an enormous
opportunity to bring some of that spend under management to gain insight to what are the
items that we’re actually introducing into our supply
chain. That will definitely let us better
understand our risk and also take better actions to mitigate risk. The last topic I would like to briefly
touch upon that was included in our RFI practice was the draft ordering procedures. Our approach
in coming up with the ordering procedures was to
maximize the flexibility that was allowed for by
law, and we had a couple of goals. One, easy. We wanted to make it easy for both our buyers and sellers. Two, compliance. We wanted to have
compliance with mandatory sources such as AbilityOne. Three, competition. We want to make
sure that we’re driving competition, both at the
e-marketplace level and the suppliers’ levels. Four, small business. We want to make
sure that we’re encouraging the utilization of
small business through this program. And, lastly, we want to make sure that
purchase decisions are being driven by best value. We recognize that there is a multitude of
factors that can drive a purchase decision, and
we want to make sure that e-marketplaces have the
capability to capture the basis for that purchase decision, but let buyers make the best value
decision. Again, we see significant opportunity
through the e-marketplace initiative to bring a
lot of open market micropurchase spend management. I look forward to your questions and continued opportunity. With this, I am going to turn it back
over to Laura for some closing remarks. MS. STANTON: Great. Thank you, Mark. Thank you, Jeff. Just I think that over — throughout
the course of all four of our comments, first of
all, I think — I hope that you understood that
we have heard and incorporated the feedback that
you shared with us. And so in that light, and in
that context, we had hoped what we wanted to do
today was really walk you through all of — not only the history, the facts, but also more
of the context, the background, and what we’re trying
to accomplish with this, and I hope we’ve
accomplished that. So with that, we have another RFI out
on the street that lays out a path forward that
we would like to ask you to comment on by December 21st, which would give us time to
incorporate it in the report that we have due to
Congress in March. So, and as we go forward with that, we
will be using that also to inform the proof of
concept, to be able to test out these procedures, this path forward, and get a sense, an answer,
all of the questions and feedback that we have
raised today. So with that, I know — I think many
of you in the audience might have a few questions for us, and so let me pass it over to Chris
to get things going. MR. AVERILL: Thank you, Laura. Thank
you, everybody. Actually, I think you answered
everything that everybody in the room might —
(Laughter.) MR. AVERILL: — have, so I’ll give
everybody time back. No. I do appreciate the
detailed and straightforward discussion that was
just had, but I’m sure we will not lack for questions. We have some microphones set up, so
please begin queueing shortly. But I will begin
with a few framing questions that I think might be on people’s minds, and then we can go to
the audience for further questions. The first thing I’d like to ask, and
I will direct this to Laura to start, and anybody
else can feel free to supplement as needed, but I
want to combine — many of you were probably here
for this morning as well, and we heard about the
consolidation efforts of the MAS program. So I want to ask how you see this
commercial platforms effort aligning with that
initiative. And, broadly, can you speak to how
this ties into the broader federal marketplace initiative? MS. STANTON: Great. Thanks, Chris. So today’s event — and I started out addressing
this — was really focused on the entire GSA federal marketplace initiative, which the
vision is, how do we improve the market — the federal
marketplace as a whole for the buyers and sellers? And so what you heard about this
morning with the MAS reform is really — and the modernizing the schedules program, is to reflect
the integrated nature of the market, where the
commercial markets moved to, and how does GSA
best support that. We view, really, this commercial
platforms initiative in the same light, in the
modernization of how simple COTS purchases are
made, specifically those made on the open market
as you heard echoed from across the four of us
today. We recognize that there is multiple
channels available to buyers, and as part of the
federal marketplace effort we have the opportunity to really refine all of GSA’s
offerings to be able to meet the buyers and the
sellers where they are. So, really, we see both the MAS
consolidation effort and the commercial platforms program as complementary to one another, and
really focused on that same goal of improving the
buying experience for the federal buyer and be
able to focus contracting officers and the acquisition workforce back on their mission. MR. AVERILL: Perfect. Let me target
this one to Matthew, and, Jeff, if you can fill
in as well a little bit. I think over the course
of this — the discussion on how to best formulate this pilot, we received questions
about whether or not we are eliminating the need
to comply with Buy American Act and Trade Agreements
Act’s regulations. Can you address that topic? MR. BLUM: Sure. Maybe I’ll go ahead
and start. And we have had a lot of
conversations, both in our public meetings and
also in some of the sessions that industry associations, coalition and others, have
sponsored. And just to maybe unpack it a little
bit, I think the question isn’t about whether the
Buy American Act or Trade Agreements Act applies as a matter of law, at least to the proof
of concept, because as we know, the law doesn’t
apply the BAA and the TAA to micropurchases. The question I think really is getting
at GSA’s decision made the corporate decision a business decision that GSA made a number of
years ago for the schedule to make sure that all
of the products on your program do comply with the
Trade Agreements Act. And so the concern I think — and you
guys are here, so you can correct me if I’m wrong
— but I think it’s premised on the assumption that the online marketplace is going to take
work away from the schedules. And by the way, this I
think is a great example of where the lack of
data creates churn and anxiety. And in the
absence of knowing affirmatively what is going on, you know, fear can fill the void. And we don’t know, but there are at
least two or three specific indicators that would
suggest to me, at least going into this, that we
shouldn’t assume that this program is going to
immediately be taking work away from the schedules. One is what Jeff mentioned earlier,
some analyses show that schedule prices are in
fact cheaper, that all of the work that GSA does up front in prequalifying contractors has
an impact. And so, once again, the rainbow is
shining over my GSA colleagues, and we have a
moment of happy silence to celebrate the good value that schedules provide. So that’s one. A second and closely related and goes
directly to what the discussion was this morning are happy customers, right? I mean, rational
behavior is that people that are happy stay with
general approaches that work for them. And GSA
isn’t trying to improve the schedules program just because they have time on their hands
and nothing better to do. They want the program to remain a
viable and go-to program that then continues to
be the largest single program we have in government for providing our buyers with access
to the commercial marketplace. So the happier
the customers are, you know, the more that they
are going to stay with those customers. And if
they’re getting good prices, all the more reason. And I think, you know, also, that at least anecdotally, but as best we can tell,
after Congress raised the micropurchase threshold,
agencies didn’t rush to just increase the authorizations on the purchase cards for all
of their purchase cardholders. There are a number
of them that have expressed some reluctance to
increase, and we think this is, you know, using
good prudence. And the fact that, you know, GSA can
offer, you know, information and insight for managers to see what is going on may make
them more comfortable. Equally important in this, though, is
for those people that are not using the schedules and are facing this risk, as they do today,
you know, GSA has appropriately asked, in its
RFI, the portal providers for information regarding
their capabilities to provide country of origin data. And I believe that the ordering procedures
also anticipate that this sort of information can
be taken into account by our buyers in making decisions about what makes sense. And that I think is an appropriate
step, because as you heard, you know, Mark and
Jeff saying a few minutes ago, with respect to
supply chain, this isn’t a passing fad. This is
something that is only going to become more important and more central to the shape of
our acquisition programs. And for those of you that have been
following the dialogue, this administration has
been working proactively with Congress on supply
chain risk management legislation that would, in
part, create a council to help rationalize lots
of the activities that are going on and bringing the main players together — DHS, DOD, DOJ,
OMB, NIST, Commerce, GSA — to have whole of
government conversations that make sure people are carrying out their supply chain risk
management responsibilities, many of which are
already kind of captured by FISMA. And equally important, making sure
people understand their roles and responsibilities in doing supply chain. And one in particular is the role of GSA. When you think
about Kaspersky and others, I think oftentimes people from — our colleagues from Congress
will run to GSA because that’s the government’s
buyer, and then expect GSA to be taking actions on
its own to solve the supply chain challenges when
in fact those responsibilities still rest with
individual agencies. Now, GSA does have a role to play in
working with agencies and in conveying information to ordering agencies, and that
is precisely what I think you have heard Mark
and Jeff talking about in terms of why data is
so important, so that managers can understand
what information is out there and make sense of
it. And to the extent that there are — there
is country of origin information, that this can
be taken into account, into the calculus. And, lastly, let me just point out
that even though small dollar, you know, should help to manage risk, we already know through
Kaspersky, you can have a $10 purchase and that can create significant risk in some
circumstances. So, again, this — this challenge,
this risk, already exists with the existing micropurchase threshold. The online marketplace
pilot isn’t creating a new risk as we have discussed it today, but hopefully it will
reduce risk by providing greater insight into our
purchases. MR. KOSES: Thanks, Matthew. I
offered some comments a few moments ago that I
think largely address our thoughts around some of
the trade rules, but let me add a couple of additional considerations. We fully understand the argument in
the data of trade agreements, the creation of
American jobs, the whole series of really good
and noble public policy that comes out of that. We have also over the last year been working
on a couple of other high-level important policy
goals. One has to do with bringing new suppliers into the federal marketplace. There is
a number of firms who, for a whole host of reasons, have not wanted to do business with
federal government. They see risk, they see
complexity, they see slow payment, they see a
host of things. GSA drafted and with — we came to the
Hill — the importance of raising the micropurchase threshold and the SAT. One of the
key benefits of that is the opportunity to bring
the non-traditional, the new suppliers, the emerging supplier, companies who have not
wanted to do business with GSA. So as we are looking at a new program,
and as we are looking at a discretionary opportunity to create those incentives, to
reduce a regulatory burden, we are at this moment
feeling pretty reluctant to start adding in voluntary regulatory restrictions not required
by law when we know that they cause impacts,
some deliberate, some unintended. Our sense is, let’s test out, let’s learn from this environment, and we can make,
of course, adjustments as we need to. MR. AVERILL: Great. Thank you both. I have one final framing question. And if anybody wants to begin lining up for
the audience, we will take them after this. But,
Mark, I will start with you. We have heard a lot this afternoon
about the importance of, and excitement around, transactional data. Could you talk a little bit
about whether GSA planned — or how GSA plans to
limit a portal provider’s ability to use proprietary information or transactional data
that is derived from third party suppliers? MR. LEE: So, I mean, that’s an issue
we’re actively seeking feedback within our RFI. So we’re clear about, in terms of data rates,
what I went through in my talk, of what is in ED3
of this year of FY19’s National Defense Authorization Act. And with any ongoing
contractual requirement, then we are going to
have to have ability to surveil that. So that is one issue that we are
looking at that currently we are abiding by the
law. There will be a contractual requirement. And then we are also looking at, how would
we monitor that requirement? We recognize that there is a
perspective, though, from the e-marketplace and
the supplier community, and, again, we are trying
to balance those perspectives. But this is an
area that we say, “Please do weigh in on the RFI
in that particular area.” MR. AVERILL: Great. Anybody from the
audience that might have a question? Very shy
group this morning, or this afternoon. Excuse
me. Okay. We have one gentleman in the
back. And if you could identify your name and
affiliation or organization, we’d appreciate it. MR. WILLIAMS: All right. I’ll start
off. My name is Burl Williams. I’m with
Integration Technologies Group. We’re a
government contractor. We’ve been in business for over 30 years. We have had the GSA schedule
for over 20. I was on GSA Advantage the other day
for an IRS requirement. And they were looking
for specific items, and I went to Advantage and
pulled up one of the items. And I know, because
I’ve been in the business for 30 years, that it
is not TAA, it doesn’t meet EnergyStar, and doesn’t meet the general contractual
requirements. But on Advantage, I can see it by —
provided by 15, 20 different vendors. And then I
go look at each individual one, and there is
different countries of origin, different descriptions. One company says Made in U.S.A.,
another one says Taiwan, and another one says Korea. There is no consistency. If you can’t keep GSA Advantage and
the current contract holders on schedule, correct
and accurate, how is this marketplace going to
manage more vendors, more openness, with similar contractual terms that the agencies require, without some type of governance and ensuring
that it’s right when GSA can’t even do it themselves
today? MR. KOSES: Okay. You know, there’s
probably two parts of that question that we should talk about separately. One is, what do we
do on Advantage today to try and oversee and enforce and ensure that the contracts indeed
are representing accurate information? And, two, how do we translate that
into the portal environment? I’m going to partially defer to Mark
on the first part and ask him to expand, but we
have continually been trying to increase our suite of tools that check and look for some
of the differences in data. A key to that has been product
standardization, getting to common part numbers, because when we add a common part number,
and we have 10 companies tell us an item is made
in Canada and one tell us it’s made in India,
or the opposite, you know, that’s some of the indications that we can use in better managing
the program and building some of the tools. I’d suggest that, again, in starting
at the micropurchase threshold, we deliberately are reducing the complexity, reducing the
challenge of the product regulation, it’s the
opportunity to also start harvesting and running with the data. This only works because of
today’s technology. That’s the only way that we
can build the compliance systems, the edits, the
controls. We have had a number of conversations
with the e-commerce operators to understand what
is possible to do from the accounts set up from
the user standpoint. Part of that then starts
taking us into some key roles within the agency all around account management structures. We
didn’t talk a whole lot about the agency piece of
this, but, clearly, there is going to be some significant agency responsibilities building
on kind of the motion of the Level 2 cardholder
of today, that there will need to be — if any agency has specific requirements, they are
going to need to start building that infrastructure
to manage and oversee that. And I guess that’s part of the
conversation that needs to continue with agencies to be meaningful. MR. LEE: Yeah. I’d like to just jump
in here a little bit about what we do to manage trade agreements for the schedules program. One,
I want to remind one — the way the policy works
is the certification requirements. So the vendor
community has the obligation for compliance. There is a number of things that GSA
actually does to manage that risk. One thing we
do in a pre-award is that actually a tool that I
have — it’s called 4P — that my office manages. It has become a widely adopted tool across
our contracting officers where it takes your proposed
price offer information and runs price analysis and supply chain risk assessments, including
Trade Agreements Act, and that is prior to award. It flags some of the items that aren’t TAA compliant and asks you to revise your offer
based on various different inferences. Secondly, in a post-award sense, we
use the same kind of data inferences and have a
dashboard that is looking at that, and we’re actually instituting some streamlined processes
to take those items off of — off of contract. Right now, we’re piloting that with items
that are not designated or improperly designated
as made in America. Three, in addition to that, we have
the initial operation community that goes out and
does supplier visits. And one of the things they
look at is your practices when it comes to the
Trade Agreements Act. Finally, part of this federal
marketplace is we’re actively looking at how we’re doing our catalog management. We have a
key initiative that is looking at our catalog capability and how we improve that across
the FAS enterprise. MR. AVERILL: Thank you both. Any additional questions from the audience? MS. COLLIER: I have a question. MR. AVERILL: Okay. MS. COLLIER: Stephanie Collier,
Federal Contracts Corp. We’re in the heavy
equipment arena, and so a lot of this initial stuff is not going to apply to us because
not many of your purchases fall under the
micropurchase threshold. But when this
e-commerce reform option was announced we started
looking into it, and we have had some conversations with some of the — okay, let’s
be honest, we talked to Amazon to see what Amazon
does. And one of the concerns that we have
is that some of these e-commerce platforms don’t
allow us to distinguish between selling to only
federal government and the commercial marketplace. And for us our — we don’t sell
commercially. Our agreements with the
manufacturers that we deal with is that we will
sell to the federal government. So for us, we would be limited at
participating in something like this because we
could not limit it to marketing only to the federal government. Is there a plan to address
that? MS. STANTON: So thank you for —
thanks for the question. The first thing I’ll
say is we have heard that concern from you and
from others. Part of the legislation does call
for commercial marketplaces that are actively out
there looking at being used by the private sector. So there is — so the intent was always
that these would be commercially available marketplaces already. The second piece of it is that by
having multiple e-marketplaces available would be
to allow for that type of negotiation and that
type of discussion between the suppliers and the
marketplaces to be able to — to be able to find
one that aligns best with the needs of your company to be able to put your catalog out
there. So by offering that level of competition also among the suppliers about
what – – which marketplaces you sell through, hopefully
some of that would be addressed. So we — that’s also a point of
feedback that we would like to receive in the
RFI. As I said, we have heard some of that in
other conversations as well. And we have been
looking at sort of — at what role does GSA play
with that. MR. AVERILL: Let me ask you, Laura —
oh, you have one? Perfect. Great. MR. SISTI: Tom Sisti, SAP. If you go
back and look at the beginning of this process when 846 was a standalone bill, you will recall
that there was concern about it being too restrictive. And after a lot of deliberation, we
came up with the language of 846, which talks about a broader look at solutions in the
marketplace, talks about broader activities on
the part of the administrator, the definition of
e-commerce in the bill, talks about solutions that are being considered. So then we fast-forward to the
implementation plan that was drafted in March, and we saw the presentation of three models. And
at the time, industry had said, you know, we are
concerned. We’re concerned because when you take
the spectrum of solutions and you say, okay, here
are three models, you run the risk of focusing on
one model, creating sort of a technological winner and a technological loser in the process,
giving people a leg up, first, to market status all those concerns. The feedback was that you heard that
thing; that’s not what you’re trying to do. Today, well, we saw the RFI, and of
course there is a focus on one of the models. But today I’m hearing, and I guess I’m trying
to validate if I’m hearing correctly. What I’m
hearing is you’re piloting one of the models, but
that’s not to say that the other models aren’t going to be implemented, number one. And, number two, that just because
you’re piloting this model doesn’t mean it’s going to be issued first, that it will be
assessed, and then there will be some kind of
context put to it and, consistent with the face
of the statute, the language on the face of the
statute, the spectrum of what you’ve laid out —
marketplace e-procurement, et cetera — will be
issued out there as a competitive model. Am I correct in interpreting it that
way? MR. KOSES: Tom, at this point, we
have evaluated several models. Our current line
of thought is that we would begin with the e-
marketplace model. That’s not saying that will
be the only model. As I said, we see a
significant value at a later stage for the e-
procurement phase. I don’t think we have reached
a conclusion on the portal pace. We have seen, we think, a substantial
value in the e-marketplace. Our current line of
thought is it makes sense to begin the first proof of concept there, but the whole idea
is piloting and experimentation and learning
from what we see in these. It is also intended to be a very
collaborative dialogue, and if we have missed some key pieces, we need to know that. That is
part of why we are having conversations of this
sort. MR. SISTI: Okay. Just to clarify my
question, because I — MR. KOSES: Go ahead. MR. SISTI: — I understand what
you’re doing on the piloting. I’m talking about
when you hit the point where you’re going to
issue — you’re going to issue a solicitation for
contracts for the solutions, are you saying that
you are only focusing on what you have defined as
an e-marketplace, thereby restricting what exists
on the face of the statute? Or are you going to
solicit them all? MR. KOSES: What we are saying is the
one that we are contemplating soliciting for first is the e-marketplace. I’m not saying that
we’re not contemplating soliciting for the others. I’m saying that the one that we are
thinking we would move first on is the marketplace. MR. SISTI: Okay. And that’s not
consistent with the statute. MR. KOSES: I don’t agree with that. MR. SISTI: Okay. Well, I’m —
MR. KOSES: But we can certainly have
a dialogue, and tell us your reasoning. MR. SISTI: That’s right. So with
that, we should put in our responses to the RFI. Correct? Yes? No? MR. KOSES: Yes. MR. SISTI: Okay. Thank you. MR. WALDRON: I mean, I think the
concern, and that’s — there is concern across industry that the pilot approach, taking first
— I actually heard about a different model today
from a company outside the three that you have
identified. So the concern is, fundamentally, that
you are pre-selecting one approach that ultimately is going to define the market,
period. And we haven’t heard anything different from
what you just said. That’s a concern from the
companies who have the e-procurement solution. That’s a concern from the companies who have
the e-marketplace solution. And you’ve done nothing
here to alleviate that concern. So we will reflect it in our comments,
but you are redefining the statute essentially by
picking a winner up front, one particular type,
when the statute’s definition is much broader. Okay? That’s the view, and it would be —
behoove GSA to explain how it’s acting consistent with the statute; they’re going down that
path to implement the e-marketplace first. I think
that’s a fair — that’s a fair observation, and I
think it’s a fair — it’s a widely held concern across industry. Okay? And then I just need to follow up on
a couple of things. I appreciate the comments,
and this is a great meeting. But you have
confirmed what we thought, that — and it’s a circular argument. The process defines what is
waived, not what is the merit of what is being waived or not being waived in terms of cost-
benefit analysis. And the process is the
micropurchase threshold. Time and time again, the reference is
the micropurchase threshold doesn’t apply these
things. There is no discussion here about the
merits of whether it’s Trade Agreements Act or
other provisions and whether those apply or should apply or not. And you can go back in the history of
GSA — and you know this — it’s not a business decision, and we had the NASA SEWP versus
GSA issue of applying the Trade Agreements Act,
where NASA SEWP used to apply it much in the way
you want to apply it in this program. And this is a
program. It’s not a set of micropurchase buys. So it’s — so NASA SEWP used to apply
it at the order level. GSA schedules, Jeff, as
you know, applied it at the — based on the value
of the contract. There is a huge debate in the procurement community as to what’s appropriate
and what’s in the best interests of the federal government. NASA SEWP now applies it at the
contract level to be consistent. And I can tell
you, when I was at GSA, I sat in meetings with
the U.S. Trade Rep when we were contemplating waiving TAA on non-availability determinations
and we were urged not to do that because of the
trade implications of it and what the USTR was
trying to do to promote fair access for American products across the globe. So here we’re creating a program that
could potentially reach the millions, tens of
millions, hundreds of millions of dollars, where
we’re not even talking about whether it should be
applied or not. We’re just saying because the
micropurchase threshold applies to a program that
could account for millions and millions of dollars of purchases, therefore, it doesn’t
apply. What we hope you do is in your report you lay out the cost-benefit analysis from
a trade perspective, from a U.S. jobs perspective,
that addresses the decision and the merits of
waiving the TAA versus having it, in the context of this, because I don’t think it’s going
to — in a large part what people look at that and
have said to me is that the statute says GSA is
supposed to provide — can provide information to
the marketplace providers for purposes of screening products or suppliers. It’s clearly in
the statute. TAA, cyber, excluded parties list,
counterfeit gray market, those are all things that the way the statute is written GSA could
theoretically be responsible for assisting buyers
in making decisions via the e-marketplace. But,
instead, what we’re doing here is we’re putting all of those decisions onto the buyer. So I think you need to look at that,
too, to see if it’s actually going to make it
easier for the buyer, or if it’s actually going
to reduce risk, and what is GSA’s appropriate role in that? Because the statute clearly
contemplates that. Thanks for your time. MR. AVERILL: All right. Thank you
for the comment. I think we have a question in
the back. MR. BURTON: Rob Burton, Crowell &
Moring. I’m curious as to why it appears as if
you are applying new rules to micropurchase. I
can understand GSA’s desire to limit this initial
phase to micropurchase, but looking at the RFI
that just came out, I think it’s rather clear that you are planning to impose new contract
clauses and new requirements to micropurchases which have never existed before. And I think most people in industry
would agree that it has always been good to have
fewer rules apply to micropurchase. And as you
know, virtually no rules apply right now. I don’t think I saw Congress
encouraging new rules applying at the micropurchase level. I’m curious as if — as to whether you think Congress did give you the
authority in this statute to actually apply new
contract clauses and rules to micropurchase. So
if you guys could just elaborate a little bit on
the idea of applying more rules to micropurchase. And also, I think I saw 30-some
clauses being applied to the e-commerce provider. Is the idea that I think you’re trying to
get them to enforce certain rules on the suppliers
on their platforms? Curious as to what role you see
the provider taking with respect to enforcement or compliance of rules on their suppliers. I
think that’s an interesting point that I’d like
to hear you elaborate on. My final concern — and I guess it’s
more of a concern than a question — is to what
extent would agencies, suppliers, e-procurement providers, what incentive do they have to
go to this portal, considering that they would be
signing up for new rules and requirements, whereas they could just deal separately, as
they are right now, without all of these new rules
and requirements. If you could address the incentive
for agencies and suppliers to use this portal. Thank you. MR. KOSES: And I’d suggest, first,
our last two comments are a great example of the
complexity and challenge of the issue that we are
talking about. In terms of new rules, I think what
we’re really talking about is new procedures in
micropurchase, not new rules imposed on industry. What you’ll actually see is, one, the
establishment of the idea of competition at the
market purchase threshold where we are asking the
buyer to look at more than one product. We are also recognizing that without
workflow, with — given the agency’s new tools to
start managing that, there are likely to be questions, and so the buyer needs some means
to document the basis for the decision. So beyond those two, Rob, I’d be
interested in what you see as a new rule. I’d
suggest we have been very conscious not to create new rules at the market purchase threshold. In terms of the clauses, we took an
extensive dive through what is required by statute, and those largely come down to statutes
that carry criminal penalties, statutes that get
into funding law, or others that are expressly required. Wherever there was discretion as to
whether or not to apply, we have had a lot of
conversations looking at the policy issue, and
does it make sense to apply something maybe the
FAR Council chose to apply to commercial end contracts but that was not required to be
done so by the statute. In general, we came down with the
decision, if it was consistent with the commercial practice, we probably want to carry
it forward. If it was not consistent with the
commercial practice, we probably did not carry it
forward. I think the last piece of your
question was about, what is the value in this for agencies? And I think we have kind of covered
that fairly heavily. What we see as the number
one value is data, getting the line of sight, the
understanding on the spend, the ability to redirect spend into preferred agency direction. There is a secondary value in
addressing some of the fear that is out there on
the part of the buyers and the P-cardholders and
others who are so sensitive to the intense oversight in this environment; that giving
them an approved channel with a backing, with
information, with support, we think offers a
significant value in the marketplace. MR. LEE: I’d just like to add, too,
that the value — I think that it is a powerful thing about having economies of scale across
government and having a program. So we know that there are other
efforts going on right there, and so we can have
further bifurcation across the government or we
can have a program that essentially manages and
does achieve economies of scale in that management. MS. STANTON: And I just want to —
and I know Matthew has a comment to add as well. Going back to the value, I mentioned that
we — that we recently had a workshop with the
agencies, and Jeff’s description of the value is
absolutely the reasons that they were interested in this, as well as going back to the whole
of government approach. But the fear — the fear of using the
purchase card is certainly out there as well as
the desire on the agencies for those who haven’t moved to the $10,000 limit, to be able to,
one, have greater confidence in what their buyers
are doing and insight into that, but then the
other piece of it is then to be able to also take
those low dollar buys off of the workforce. Jeff addressed many of the same things
that came up in the — covered all of the items
that came up in that agency discussion when he
walked through his value proposition earlier during his remarks. MR. BLUM: You got everybody on the
panel to react. That’s why he’s a good lawyer. So I would just, I mean, I think
everything that my colleague said makes sense. And just, again, going back for a moment,
it took a number of years for Congress to decide to
raise the micropurchase threshold. And while I don’t
want to open this Pandora’s Box today, you know,
the reaction from the community to the administration’s proposal to raise the threshold
to $25,000 for this program, I think what it
signaled to us is that there is a pretty significant difference in the world of
micropurchase from even simplified procedures. And the world that we have created of
1994 is a little different for the purchase cardholders today on the online — you know,
whether they are using the online marketplace or
just going out on the internet on — on their own
through any other tools that the agency provides. And as a policy matter, I think we do
need to do a little thinking about what is the sweet spot of, you know, what is a smart use
of technology to make smart buying decisions,
because if we — if purchase cardholders make dumb decisions, nobody wins. And, you know, the
authority will be scrutinized and perhaps we will
move backwards. But I do appreciate Rob’s point that
the challenge also is to see this as an opportunity for where we can alleviate burden
on our contracting officers. Somebody made the
point the other day, which I think I’ve had in
the back of my head for a number of years, if you
go back to the 1990s and acquisition reform, one
of the significant changes that was made, if you
recall, we used to have 1105s — I think that was
the job series; they were like procurement clerks
— that did a lot of the — kind of the lower dollar clerical-type procurement activities
that needed to be conducted. And I think it’s a good kind of point
to keep in the back of our minds because if you
look at the average portfolio of a contracting officer today versus in the early ’90s or
late ’80s, I think you will see that they have
a lot more on their plates. Now, it’s not all just because of the
loss of the 1105s, but I think that’s part of it,
and that’s oftentimes what gets cited back to us;
that, you know, if a contracting officer had 10
very complicated procurements, you know, in the
old days, now they have that plus they have a
whole plate of other activities that they have to
tend to. And what does that do? That reduces
their time to think about the complex procurement. So we do have to think carefully
about, you know, what we’re imposing on folks, but I think there is a benefit — and I think
Jeff stated it well — of making sure that there
is some sort of appropriate guardrails in what we
expect of our cardholders to ensure that once this activity is transitioned to them that
people are confident, and all of us, you know, as
stewards of the taxpayer dollars are doing smart things with the card. MR. AVERILL: Great. Thank you all. Before we close on this portion, I do want
to ask Laura to give a little bit of a sneak preview,
reminder, highlight of what the upcoming timeline is. In particular, Laura, if you can maybe
reiterate some of the points of opportunity for
industry to be engaged. You know, we have the
report coming due to Congress in March, but Congress will have an opportunity to further
clarify and we can provide further inputs to
them. So if you want to highlight sort of,
to the points that have been made today, the further opportunities for input and dialogue
and discussion to make sure that we are shaping
this appropriately, that would be great. MS. STANTON: Thanks, Chris. All
right. I think if nothing else, you should be
walking out of here and realize that we want to
hear from you, and we take that feedback very seriously. With that in mind, a couple of key
dates. December 21st is when we’re asking for
the feedback on the RFI. And the reason for that
— for the short timeline on that is really to
give us time to incorporate it into the report that is due in March of 2019. So we’ll be over the holidays and into
early January very much working through all of
the feedback that you share with us, incorporating that into the March report. I
realize March may sound like it’s a long ways away, but in the world of having to get things
signed off, it’s not that far away. So we have to have everything wrapped
up in the January timeframe to — in order to go
through the appropriate review process between GSA and then pass it over to Matthew to herd
it through OMB on our behalf, to make sure that
we have that mid-March delivery. And the Hill is waiting for that. We
had an opportunity to speak with them recently about it. Meanwhile, at the same time that we’re
working on the report, that feedback that you are
sharing with us is also going to be going into
the draft solicitations — solicitation that we
mentioned to start the proof of concept. So after the draft — after the report
is released in March, soon thereafter you will
see a draft solicitation to support the proof of
concept, to get us to the multiple e-marketplaces that we talked about today or to — or some
refinement thereof. And so we want to be able to have that
proof of concept in place by the end of the calendar year 2019, so we can begin to get
the agencies who are interested in engaging with
us up and running as soon as possible and begin
to answer some of the questions that have been
cited here today. So thank you very much, again, for
joining us on this journey, and we are partway through and we still have a ways to go. So I hope that you will continue to join us. MR. AVERILL: Thank you, Laura. And
if you wouldn’t mind joining me in a round of
applause for our panelists today. (Applause.) MR. AVERILL: Before we close, I
believe we have one final guest who should be
here now, FAS Commissioner Alan Thomas. But
before we hand it over to him, we’d like to thank
everybody for being here — one more, one more —
and thank Secretary Zinke of the Department of
Interior for allowing us to use this beautiful space. And thank you all, in particular, for
your participation, your questions, and your further input and dialogue. So thank you. Alan.

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