All Things of Interest to the Government Contracting Community

FSSI Act Now!

I am submitting the following comments and feedback to FAR Case 2015-015 starting with high level recommendations and followed with detailed comment.

Maintain existing FSSI programs and place a temporary hold on the implementation of all other pending and future FSSI programs.

The Federal Acquisition Service (FAS) official Tiffany Hixson, on August 2, 2016, said, “We’ve [FAS] spent the better part of last year opening up the Gateway to industry,” she said, “and we have probably not zero, but almost zero, feedback from industry.” In that the government has publicly stated that the strategy and implementation of the FSSI program / strategic sourcing / category management is being performed absent industry feedback, it’s clear that the FSSI program should be put on temporary hold until industry feedback is obtained.

Develop a complete cost-benefit analysis that takes both sides of the value chain / supply chain into account (Government and Industry). This analysis should be outsourced to a third party that specializes in strategic sourcing; a senior consultancy that is not partial to either side.

The cost-benefit analysis should take into account, not limited to, government cost efficiencies, procurement streamlining, administrative analysis, industry / vendor zone and geographical impact, job loss, and company impact.

The cost-benefit analysis should also take into account the metrics, processes, and lessons-learned by the states of California and Pennsylvania. Both CA and PA implemented state-wide strategic sourcing programs. Both states terminated their programs for multiple reasons, including a failure to conduct a complete cost-benefit analysis prior to implementation and an on-going cost-benefit analysis to ensure the program balanced state and industry value.

Before updating the FAR, the government has an obligation to ensure that there is a balance between government and industry. Clearly, based on the fact that we’re talking tax payer dollars, the scale cannot and should not be balanced equally. Current implementation of FSSI shows little if any balance for industry and the small business community. For example, we have some level of government data on FSSI OS2/OS3 (office supplies) and no data yet on JanSan which has been awarded but not yet implemented. JanSan spend will be at least twice that of OS2/OS3 and we’re still only looking at less than one percent of total government appropriations. Now is the time to balance FSSI before thousands of other small companies are impacted like the majority of small businesses that were impacted by OS2/OS3.