All Things of Interest to the Government Contracting Community
FSSI: Coming To A Category Near You?
We are happy to report that GovConectx Partner, Richard Lewis, Financial Engineering Counselors Ltd. has contacted Virginia's Senator Warner regarding this important issue.
Senator Warner has contacted GSA asking that they review this issue and get back to him with "a detailed and appropriate response." As soon as he receives this reply, he will share it with Richard and we will share it with you.
This was not a form letter. It specifically addressed the FSSI issue with GSA and FAR.
"The exclusion of small businesses to compete for federal contracts is an assault on the original intent of the law and a threat to businesses nationally," says Guadarrama. "Consolidation of contracts to a handful of chosen vendors will likely result in bankruptcies and certainly the loss of thousands of jobs."
Charles Tiefer, Commissioner (2008-2011) on the Congressionally Chartered, Independent Commission on Wartime Contracting in Iraq and Afghanistan, says the FSSI proposal is, "blatant and undeniably illegal." Tiefer also serves as a law professor at the University of Baltimore.
According to Guadarrama, since consolidation began, government contracts have become larger, opportunities have dramatically decreased, both resulting in a significantly negative impact on small businesses. FSSI is responsible for office supply companies reduced from 569 to 15; government services reduced more than two thousand small business vendors to 123 small businesses: janitorial services reduced from 540 to 15 companies; and General Services Administration maintenance and repair shrank from 418 to 10. Thousands of small businesses may be left with unused and useless supply schedule contracts.
Robert A. Burton, former Deputy Administrator of the Office of Federal Procurement Policy, effectively the nation's highest procurement policy figure, who reviewed the FSSI changes and testified on Capitol Hill said, "Small businesses have not just lost, but have done so on a devastating scale."
Tiefer says there is ample evidence the distribution of small business contractors has catastrophically shrunk, withered and dwindled and believes, "the proposed regulations would reduce the breadth of small business contracting by up to 80 percent or even 90 percent in lines of business where small business contracting is currently common."
http://thehill.com/regulation/business/291722-small-businesses-fear-rule-changes-will-crater-federal-contract-chances#disqus_thread
Prof. Samuel D. Bornstein
Bornstein & Song FSSI Research:Federal Strategic Sourcing and Category Management Loading
This is a critical time because there is a move to amend the FAR by making FSSI "Mandatory."
Here are two key points to consider:
1) April 5, 2016 letter from House Small Business Committee Chair Chabot and Ranking Member Velazquez to the GSA Administrator Roth, expressing their concern about Category Management and how FSSI has hurt small business.
2) Proposed Rule in the Federal Register (June 20, 2016) to amend the FAR by making FSSI effectively "mandatory" for all federal procurement. This will pave the way for FSSI as a key precept of Category Management which will impact $277 billion in annual government spending. If successful, this will be the death knell for all small business federal contractors.
Under this Proposed Rule...Contracting officers may have to explain why they're not using the Federal Strategic Sourcing Initiative. The Federal Acquisition Regulatory Council proposed this Rule requiring officers to show a comparison of purchases made with ones available under the FSSI when it's not used.
We must coordinate an effort to "bring this out into the open". Unfortunately, it is going "under-the-radar" and few are aware of this development which will jeopardize their business survival.
for more info:
www.bornsteinsongFSSI.com
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What You Can Do:
Write your Congressman and Senator
or
Write your own