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HORAN. GSA SER. Well, the method I would like then to figure it out is if it in fact produces a better value, finest value to the government, considering the expense to the specialists. I do not believe they can do that based upon the way in which the proposed guideline is carried out here.

Small services are understood for the added worth they can supply agencies with advantages such as client service. Big corporations or big companies can not do that. Mr. Horan, you specified in your testament that the brand-new guideline does not represent such included worth. GSA SER Software. What could this omission suggest not only to little vendors however also to the firms that acquire their goods and services? Mr.

I think those other terms that cause finest value could be lost. Once again, that it could be-- the procurement might be driven to low cost only, and as a result of that, the specialists who use some of these other terms and services that offer best value will lose sales at a minimum, maybe be driven out of the marketplace.

Due to the fact that they are out of the business or they are simply not bidding anymore? Because they are out of the organization. Because there is such pressure on contracting officers to look at only low rate that sometimes they will omit consideration of best value however ultimately, I believe they might be out of the service.

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The quotient for federal government procurement survey in its survey, small businesses suggest that it would take on average 232 hours to comply with the GSA's proposed rule. Mr. Stanford, has your company done its own estimate on the hours it will take to comply with the new requirement, and do you find the outcomes of the survey to be more accurate than GSA's own analysis? And while we have looked at their research study and the ABA work, we are also encouraged in accepting their conclusion due to the fact that likewise SBA Workplace of Advocacy and GSA's own inspector general determined that those costs appear understated.

Other than our spin on compliance, can you go over some other expenses that companies like yours will have to face since of this guideline? I will not speak to our business separately, but speaking to the business we work with as they go into the federal market, the expenses beyond compliance are-- for little businesses are preliminary expenses up front.

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Mentioning the cost of upgrading its data systems, GSA is proposing to ask vendors to report to GSA the details of what was acquired through GSA. This resembles asking merchants selling through Amazon to report to Amazon what it sold, through Amazon. To take this example one step further, Amazon would then use that information to promote rates to other consumers, on Amazon.

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While not a perfect comparison, GSA in numerous ways operates as an Amazon-like part of the acquisition process. The intent behind this guideline is looking for to make a best-in-class contracting market. Yet, GSA has decided to hand down investing in a data collection system that might collect this information automatically.

II. The Rule Imposes a Significant, Underestimated, and Unnecessary Problem GSA estimates that it will take six hours for a specialist to achieve all jobs needed to comprehend the reporting requirements, prepare its systems and workers, and establish the treatments essential for developing the required reports, and a typical 31 minutes per month for ongoing reporting. 2 GSA does not offer enough detail to examine how these price quotes are flawed, but essentially every notified party who has weighed in on these price quotes thinks they are unreliable.

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Reg. 11625. The Small company Administration's Workplace of Advocacy reports that little businesses and their agents are concerned that GSA "under estimates the problem and resources." 3 The Council of Defense and Area Market Associations views the estimates as "grossly ignored,"as failing to "account for pricey modifications to info systems that will be required to properly and completely capture the information elements required by the guideline"or to "sufficiently represent the time needed to perform quality control on draft submissions and investigation into possible data abnormalities that regularly occur with transactional data reporting." 4 Based on its experience with pre-award audits of specialist systems, the GSA Workplace of Inspector General "question [s] whether GSA's quote of 6 hours per contractor to configure their systems for reporting is accurate"and "compete [s] the predicted concern of month-to-month reporting as 0.

Otherwise, the professional will risk a claims of scams under the False Claims Act, as has actually held true with basically every other form of cost or expense reports submitted by a professional to the federal government. Importantly for this hearing, small businesses will bear the largest part of this problem-- GSA approximated that out of 15,738 suppliers holding contracts that would be subject to this Rule, 12,590 are little businesses (GSA SER Software).

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Reg. 8 GSA likewise recognizes a point extremely essential to industry-- that price paid is only of lots of "info points"in identifying the best worth to the federal government. 10 We can also include customer service, item support services, guarantee, and other terms to this list.

According to GSA's own analysis, this burden enforced on specialists will supply the government with only one of the needed information points-- transactional cost-- without any methods to acquire the other info points essential to evaluate cost. Without access to, and factor to consider of, this other essential details, the rate information is of little worth at finest and can be extremely misleading at worst.

In my view, the inability of the Guideline to capture these other non-price aspects could be specifically harmful to small companies. Small companies frequently operate as value-added resellers or otherwise identify themselves in the competitive market based on the worth they contribute to a transaction, such as customer and item service capability, that is not recorded by deal price.