Simplified Acquisitions were one of the purchasing methods that helped me land my first few big deals when I was a rookie inside salesman for Pulsar Data Systems many years ago. Given the dramatic increase in spending since FY2009, I appreciate the level of attention being given to Simplified Acquisition's and Small Business by the Government.
I'm almost hopeful agencies will once again use this acquisition method as a proving ground for small federal contractors seeking to prove themselves on these lower risk opportunities, with the aspiration of moving on to larger requirements.
I said almost.
For many years, simplified acquisitions has been part of the daily dialogue at The American Small Business Coalition. Long before it was socially acceptable to discuss that subject in industry circles. Huh? Really? Sorry folks, my mistake. I was just told it's still not acceptable. Never mind.
I mean let's face it, we've all been conditioned to look to the skies for hundred million dollar and billion dollar opportunities, never mind this insignificant and bothersome stuff.
Want to know how insignificant these purchases are?
If you combine the total purchasing dollars from FY2011, FY2012 and FY2013, the total adds up to more than was spent this way by the Government during the ten year stretch from FY2000 through FY2010. For comparison, that would be $32.1B versus $30.5B in simplified acquisition spending.
Hmm. Not so insignificant all of a sudden.
To head off all the questions that routinely follow these blog posts, these purchases were for goods and services. For a look at the diversity of the purchases, in FY12, more than 1,000 NAICS Codes were used to achieve $15B in simplified acquisition spending.
But here's the real point I want to make in this entry.
I was doing some of my routine research and updating my presentation for our market research workshop (Ethical Stalking for Government Contractors) and saw a new simplified acquisition report had been added to FPDS-NG. The description of the report cites "The purpose of the Simplified Acquisition Threshold Report is to provide
Funding Agencies with a tool they can use to analyze their small
business performance on contracts within the Simplified Acquisition
Threshold (SAT), $3-150K range. Contracts within the SAT are reserved
for small business (SB) per 15 USC Sec. 644(j)(1) and FAR 13.003(b)(1)."
It also specifies three conditions that apply to the report. The first one is what caught my attention. It reads:
The following conditions will apply to this report:
SAT Condition: Only final base (modification number = 0) actions
with cumulative "Base and All Options Value” as greater than $3,000 and
less than or equal to $150,000 will be included.
Okay that's nice, but what about all of the purchases competed using the Simplified Acquisition Procedures that exceed $150,000 per cumulative action? The Test Program for Certain Commercial Items (FAR Subpart 13.5) allowed agencies to award competed or non-competed SAP buys valued up to $6.5M before that rules' untimely death in January 2012. Actually, scratch that, Congress is trying to bring that exception back to life in the 2013 NDAA.
In FY11 over $9B in simplified acquisition awards were made where each cumulative action exceeded $150K. As I read this report, none of those actions would make the cut based on the current conditions being applied.
I am very open to someone showing me where I am mistaken in my interpretation of this report, but if it's purpose is to give agencies a useful tool they can use to analyze their small business performance, the conditions should be based on purchases competed and not competed under the simplified acquisition procedures, not just those that fall within the simplified acquisition threshold.
Peace.The Chief Visionary
"The person who says it cannot be done should not interrupt the person doing it."
Differentiate Yourself. Develop and Leverage Your Small Business C4ISR™.
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