Hey Fellows! Why make Simplified buys EZ?
Thursday, February 21, 2013
Posted by: Guy Timberlake (theasbc.org/visionary)
I really do miss the old Batman television show with Adam West and Burt Ward, cheesy as it was. Actually, I miss the villains, especially Frank Gorshin's "Riddler" and his taunting brain-teaser's that often started with "Riddle me this Batman!" That stuff was classic!
On to the serious stuff now.
With bated breath, I have been waiting for something more (anything more) to come from the RFP-EZ project which is cited as a "signature project of the Presidential Innovation Fellows program" by my friend Matthew Weigelt in his Jan 31 FCW article. During this period of waiting, I have reviewed information about RFP-EZ to understand it's purpose and related benefits. I'm always a fan of anything that will create efficiencies for government contracting, specifically how Government and Industry do business, and of course, if it benefits small business in some way.
So after reading and pondering and reading some more, I've come to this point.
Riddle me this Presidential Innovation Fellows!
Why are you trying to make "EZ'r" (sorry!) a process that is already streamlined?
On your page for Project RFP-EZ you specifically discuss: "The projects inside of RFP-EZ are only "simplified acquisition threshold” projects. This means that they qualify for simpler procurement procedures because the value of the contract is in a certain range – in this case between $3,000 and $150,000."
The Simplified Acquisition Procedures exist (among other reasons) to reduce administrative costs and avoid unnecessary burdens for agencies and contractors. So in all sincerity, what can you possibly do to effect positive change to this already simplified process?
Will it be in the areas Steve Kelman describes in his recent op-ed to FCW where he talks about "Relative weights for evaluation factors (such as price and past performance) do not need to be specified in the solicitation, and evaluation itself is simplified. Past performance judgments may be based on the contracting officer's own knowledge or based on customer surveys, rather than requiring a more formal process."
I don't mean to be a skeptic, but I have to believe this falls under the category of trying to fix something that isn't broken. I don't mean to profess the Simplified Acquisition Procedures are perfect, but purchasing activity under these procedures have increased greatly in recent years (from $3.8B in FY09 to $15.5B in FY11). Is that what this is all about?
If the goal is to make things "EZ" for agencies and contractors in the area of smaller and lower risk opportunities, I vote we adopt an idea Mr. Kelman published shortly after OFPP's Joe Jordan issued his Maximizing Opportunities Under the Simplified Acquisition Threshold for Small Businesses memo on June 6, 2012.
It goes something like this:
"Raise the micropurchase threshold to $250,000 for the first five contracts a new small-business entrant into the federal marketplace has with federal customers.Why the micropurchase threshold? Purchases below the micropurchase threshold are not subject to any government-unique requirements of the kind that often scare commercial businesses from entering the federal marketplace. The government can make a decision to go with a vendor without any complex requests for proposals or proposals of the kind that also often scare small new businesses off from federal work."
That would be much easier than what appears to be happening with Project RFP-EZ.
Or we can go with my idea of making all purchases made using Simplified Acquisition Procedures set-aside (versus reserved) for small business, and raise the Simplified Acquisition Threshold to $500K.
All of you giving me the hairy eyeball should back off because I was being nice. I could have said to raise the threshold to the limit of the recently re-authorized test program that allows agencies to leverage simplified procedures to make buys of up to $6.5M for certain commercial items.
I could have.
The Chief Visionary
"The person who says it cannot be done should not interrupt the person doing it."
Visibility and Opportunities for Growing Small Federal Contractors. SAP Task Force™.