JUN 1 G 2016

MEMORANDUM FOR DONNA M. JENKINS ASSISTANT COMMISSIONER

GSA Office of Govornmen!wide Polley

OFFICE OF ACQUISITION MANAGEMENT (QV)

FROM:

SUBJECT:

JEFFREY A. KOSES SENIOR PROCUREM OFFICE OF ACQUISI

GSAR Class Deviations in Support of Competitive Pricing Initiative/Formatted Product Tool

Pursuant lo the authority in General Services Administration Acquisition Manual (GSAM) 501.404(c), the attached request for a dass deviation to initiate the Competitive Pricing Initiative (CPl)!Formatted Pricing Tool (FPT) pilot Is approved. This class deviation authorizes contracting officers to deviate from the clauses outlined in the attached request dated June 7, 2016, as shown below, including alternate versions of these clauses where appropriate:

• 552.211-78 Commercial Delivery Schedule (Multiple Award Schedule) • 552.216-70 Economic Price Adjustment- FSS Multiple Award Schedule Contracts • 552.238-71 Submission and Distribution of Authorized FSS Schedule Prtcellsts • 552.238-72 Identification of Products that have Environmental Attributes • 552.238-81 Modification (Federal Supply Schedule)

I. Background:

The upcoming Formatted Product Tool (FPT) Within eOffer/eMod will automate the publication of GSA Schedule price lists, rendering unnecessary the existing requirements for contractors to submit electronic and paper copies of their GSA Schedule price lists. The Federal Acquisition Service (FAS) therefore requested a deviation from five provisions and clauses to remove or update outdated language to accommodate FPT.

II. Justification:

This deviation will decrease costs on contractors or offerers and will make new technology available faster through GSA Advantage, as it eliminates the requirement to provide GSA Schedule price list information twice. Instead, contractors will only be required to submit to submit this information once. Given the complexity of the new CPllFPT tool, it is Tikely FAS will encounter challenges when implementing these system updates.

U.S. General Services Administration 1800 F Street. I-NV Wastllngton, DC 20405-0001 www.gsa.gov

However, the potential benefit of the Competitive Pricing Initiative/Formatted Pricing Tool (CPllFPT) is clear. With successful implementation, contractors will benefit from the process improvements around publishing their price lists, while customers will have faster access to new offerings and will also be able to obtain better structured data to make their purchasing decisions.

A quarterly progress update briefing is required over the next 12 months.

Ill. Permanent GSAR Changes:

As FAS intends to permanently remove requirements for GSA Schedule contractors to separately submit electronic and paper copies of their price lists, a General Services Administration Acquisition Regulation (GSAR) change will be required. This deviation will be replaced by GSAR Case 2016-G502, Submission and Distribution of FSS Price Lists. There is no need for a separate business case submittal to open the GSAR case.

N. Point of Contact:

Questions regarding this memorandum should be directed to Mr. Matthew McFarland, Senior Policy Advisor, General Services Acquisition Policy Division (MVAC), at matthew.mcfarla nd@gsa.aov.

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Attachment 1

Proposed changes to the current text are shown by [additions] and deletions.

1. 552.211-78 COMMERCIAL DELIVERY SCHEDULE (MULTIPLE AWARD SCHEDULE) (FEB 1996) [ EVIA l110N JUN 2016

(a) Time of Delivery. The Contractor shall deliver to destination within the number of calendar days after receipt of order (ARO) in the case of F .0.8. Destination prices; or to place of shipment in transit in the case of F.O.B. Origin prices, as set forth below. Offerers shall [indicate in eOffer/eMod] insert in the "Time of Deli¥ery (days ARO)° solumn in the schedule of Items a definite number of calendar days within which delivery will be made. In no case shall the offered delivery time exceed the Contractor's normal commercial practice. The Government requires the Contractor's normal commercial delivery time, as long as it is less than the "stated" deli¥ery time(s) shown eelow. If the Offeror does not insert a delivery time in the schedule of items, the Offerer will be deemed to offer delivery in accordance with the Government's stated delivery time[.], as stated eelow:

Go¥emment's States Items aF Gmups of Items Deli"e~· VJ (SJ3ecial Item NumbeFS OF +ime ContraGtoF's Narmal Gommeroial

Nomenclatur-e) (Days iA~RG) Deli¥ePJ +ime

* * * * -

* * * * -* * * * -

(b) Expedited Delivery Times. For those items that can be delivered quicker than the delivery times iA [indicated per] paragraph (a), above, the Offerer is requested to iAseR below, [indicate in eOffer/eMod] a time (hours/days ARO) that delivery can be made when expedited delivery is requested.

ITEM OR GROUP GF l+EMS Expedited delivery tiFRe (SPECIAL lteFR No. of

(Mo1:1FSJQays iA~RO) -- - .. ·--\ ·- ~

_,

- -- -- -

(c) Overnight and 2-Day Delivery Times. Ordering activities may require overnight or 2-day delivery. The Offeror is requested to aRAotate its prise-tist or by separate attachment identify [indicate in eOffer/eMod) the items that can be delivered overnight or within 2 days. Contractors offeriAg such delivery services will be required to state in the cover sheet to its f'.SS price list details coAceming this service.

2. 552.216-70 ECONOMIC PRICE ADJUSTMENT- FSS MULTIPLE AWARD SCHEDULE CONTRACTS [ l!>EVl~qil ' N JUN 20 6 (SEP 1999) (Al TERNA TE I -SEP 1999)

Price adjustments include price increases and price decreases. Adjustments will be considered as follows:

(a) Contractors shall submit price decreases anytime during the contract period in which they occur. Price decreases will be handled in accordance with the provisions of the Price Reduction Clause.

(b) Contractors may request price increases to be effective on or after the first 12 months of the contract period providing all of the following conditions are met:

(1) Increases resulting from a reissue or other modification of the Contractor's commercial catalog/pricelist that was used as the basis for the contract award.

(2) No more than three increases will be considered during each succeeding 12-month period of the contract.(For succeeding contract periods of less than 12 months, up to three increases will be considered subject to the other conditions of this subparagraph (b )).

(3) Increases are requested before the last 60 days of the contract period.

( 4) At least 30 days elapse between requested increases.

(c) In any contract period during which price increases will be considered, the aggregate of the increases during any 12-month period shall not exceed * * percent of the contract unit price in effect at the end of the preceding 12-month period. The Government reserves the right to raise the ceiling when market conditions during the contract period support such a change.

(d) The following material shall be submitted with the request for a price increase:

(1) A copy of the commercial catalog/pricelist showing the price increase and the effective date for commercial customers.

(2) Commercial Sales Practice format regarding the Contractor's commercial pricing practice relating to the reissued or modified catalog/pricelist, or a

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certification that no change has occurred in the data since completion of the initial negotiation or a subsequent submission.

(3) Documentation supporting the reasonableness of the price increase.

{e) The Government reserves the right to exercise one of the following options:

(1) Accept the Contractor's price increases as requested when all conditions of (b), (c), and (d) of this clause are satisfied;

(2) Negotiate more favorable discounts from the new commercial prices when the total increase requested is not supported; or,

(3) Remove the product(s) from contract involved pursuant to the Cancellation Clause of this contract, when the increase requested is not supported.

(f) The contract modification reflecting the price adjustment shall be signed by the Government and made effective upon receipt of notification from the Contractor that the nevi catalog/pricelist has been mailed to the addressees previously furnished by the Contracting Officer, provided that in no event shall such price adjustment be effective prior to the effective date of the commersial price increases. The increased contract prices shall apply to delivery orders issued to the Contractor on or after the effective date of the contract modification.

3. 552.238-71 SUBMISSION AND DISTRIBUTION OF AUTHORIZED FSS SCHEDULE PRICE LISTS [DEVIATION Jl:JN201§)]

(a) Definit!OR. For the purposes of this clause, tho Mailing List is * • {{JoRtractiRg officer 8f:tall iRseFI either: "t/:le list of addressees provided to t/:le CORtFaGtor by t/:le CDRtraetiRg OffiGer" or "t/:le CoRtraelor's !istiRg of its ~fleral GoverRment GfJstomers'7.

(b) Tho Contracting Officer will return one copy of the Authorized FSS Sehedule Pricelist to the Contractor with the notification of eontract av1ard.

(1) Tho Contractor shall provide to the GSA Contrasting Officer:

(i) Two paper copies of Authorized FSS Sehedule Prieelist; and

(ii) The Authorized fSS Schedule Pricolist on a eommon use electronic medium.

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The Contracting Officer will pro11ide detailed instructions for the electronic submissiGR with the award notification. Some structured data entry in a prescribed format may be required.

(2) The Contractor shall pro11ide to eaoh addressee on the mailing list either:

(i) One paper copy of the Authorized FSS Schedule Price List; or

(ii) A self addressed, postage paid en11elope or postcard to be returned by addressees that want to receive a paper copy of the pricolist. Tho Contractor shall distribute price lists 11.1ithin 20 calendar days after receipt of returned requests.

(3) The Contractor shall advise each addressee of tho availability of pricelist information through the online Multiple h•.iard Schedule electronic data base.

(c) The Contractor shall make all of the distributions required in paragraph (c) at loast15 calendar days before tho beginning of tho contract period, or within30 calendar days after receipt of the Contracting Officer's approval for printing, v.ihichevor is later.

[(a) At the time of offer submission, an electronic version of proposed prices, including terms and conditions, will be submitted utilizing the templates in eOffer. If necessary, eOffer will facilitate the revision of proposed pricing or price-related terms and conditions during the evaluation process. Upon award of a contract, eOffer will use the submitted pricing information to create the Contractor's Authorized Federal Supply Schedule Price List and post it to GSA Advantage!.]

(El[b]) During the period of the contract, the Contractor shall provide one copy of its Authorized [Federal Supply Schedule) FSS Sohedule Pricelist [List] to any authorized schedule user [eligible ordering activities]; upon request. Use of the mailing list for any other purpose is not authorized.

(a) Several laws, Executive orders and Agency directives require Federal buyers to purchase products that are less harmful to the environment, when they are life cycle cost effective (see FAR Subpart 23. 7). The U.S. General Services Administration (GSA) requires contractors to highlight environmental products under Federal Supply Service schedule [Schedule (FSS)] contracts in various communications media (e.g., publications and electronic formats).

(b) Definitions. As used in this clause -

Energy-efficient product means a product that -

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(1) Meets Department of Energy and Environmental Protection Agency criteria for use of the ENERGY STAR [reg) trademark label; or

(2) Is in the upper 25 percent of efficiency for all similar products as designated by the Department of Energy's Federal Energy Management Program.

GSA Advantagef> is an online shopping mall and ordering system that provides customers with access to products and services under GSA contracts.

Other environmental attributes refers to product characteristics that provide environmental benefits, excluding recovered materials and energy and water efficiency. Several examples of these characteristics are biodegradable, recyclable, reduced pollutants, ozone safe, and low volatile organic compounds {VOCs).

Post-consumer material means a material or finished product that has served its intended use and has been discarded for disposal or recovery, having completed its life as a consumer item. Post-consumer material is part of the broader category of "recovered material." The Environmental Protection Agency (EPA) has developed a list of EPA-designated products in their Comprehensive Procurement Guidelines (CPGs) to provide Federal agencies with purchasing recommendations on specific products in a Recovered Materials Advisory Notice (RMAN). The RMAN contains recommended recovered and post-consumer material content levels for the specific products designated by EPA (40 CFR part 247 and http://www.epa.gov/cpg/).

Recovered materials means waste materials and byproducts recovered or diverted from solid waste, but the term does not include those materials and byproducts generated from, and commonly reused within, an original manufacturing process (Executive Order 13101and42 U.S.C. 6903 (19) and http://www.epa.gov/cpg/). For paper and paper products, see the definition at FAR 11.301 (42 U.S.C. 6962 (h)).

Remanufactured means factory rebuilt to original specifications.

Renewable energy means energy produced by solar, wind, geothermal, and biomass power.

Renewable energy technology means -

(1) Technologies that use renewable energy to provide light, heat, cooling, or mechanical or electrical energy for use in facilities or other activities; or (2) The use of integrated whole-building designs that rely upon renewable energy resources, including passive solar design.

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(c) (1) The offeror must identify products that

(i) Are compliant with the recovered and postconsumer material content levels recommended in the Recovered Materials Advisory Notices (RMANs) for EPA-designated products in the CPG program (http://www.epa.gov/cpg/);

(ii) Contain recovered materials that either do not meet the recommended levels in the RMANs or are not EPA-designated products in the CPG program (see FAR 23.401 and http://www.epa.gov/cpg/);

(iii) Are energy-efficient, as defined by either ENERGY STAR [reg] and/or FEMP's designated top 25th percentile levels (see ENERGY STAR [reg] at http://www.energystar.gov/and FEMP at http://www.eere.energy.gov/);

(iv) Are water-efficient;

(v) Use renewable energy technology;

(vi) Are remanufactured; and

(vii) Have other environmental attributes.

(2) These identifications must be made in each of the offerer's following mediums:

(i) The offer itself.

(ii) Printed commercial catalogs, brochures, and pricelists.

(iii) Online product website.

(iv) Electronic data submission for GSA Advantage!®-submittod via GSA's Schedules Input Program (SIP) software or tho Electronic Data Interchange (EDI). Otterors can use the SIP or EDI methods to indicate environmental and other attributes for each product that is translated into respective icons in GSA Ad't'aRtage!®. [Authorized FSS Price List. eOffer allows offerors to indicate environmental and other attributes for each proposed product. These attributes are captured and reflected via the appropriate icons in GSA Advantage! when the Authorized FSS Price List is automatically posted upon contract award.)

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(d) An offeror, In identifying an item with an environmental attribute, must possess evidence or rely on a reasonable basis to substantiate the claim (see 16 CFR part 260, Guides for the Use of Environmental Marketing Claims). The Government will accept an offeror's claim of an item's environmental attribute on the basis of

(1) Participation in a Federal agency-sponsored program (e.g., the EPA and DOE ENERGY STAR [reg] product labeling program);

(2) Verification by an independent organization that specializes in certifying such claims; or

(3) Possession of competent and reliable evidence. For any test, analysis, research, study, or other evidence to be "competent and reliable," it must have been conducted and evaluated in an objective manner by persons qualified to do so, using procedures generally accepted in the profession to yield accurate and reliable results.

5. 552.238-81 MODIFICATION (FEDERAL SUPPLY SCHEDULE) (APR 2014) [ EVIA ION JUN 2016 ~

(a) General. The Contractor may request a contract modification by submitting a request to the Contracting Officer for approval, except as noted in paragraph (d) of this clause. At a minimum, every request shall describe the proposed change(s) and provide the rationale for the requested change( s ).

(b) Types of Modifications.

(1) Additional items/additional SJNs. When requesting additions, the following information must be submitted:

(i) Information requested in paragraphs (1) and (2) of the Commercial Sales Practice Format to add SINs.

(ii) Discount information for the new items(s) or new SIN(s). Specifically, submit the information requested in paragraphs 3 through 5 of the Commercial Sales Practice Format. If this information is the same as the initial award, a statement to that effect may be submitted instead.

(iii) Information about the new item(s} or the item(s) under the new SIN(s) must be submitted in accordance with the request for proposal.

(iv) Delivery time(s) for the new item(s) or the item(s) under the new SIN(s} must be submitted in accordance with the request for proposal.

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(v) Production point(s) for the new item(s) or the item{s) under the new SIN{s) must be submitted if required by 52.215-6, Place of Performance.

(vi) Hazardous Material information (if applicable) must be submitted as required by 52.223-3 (ALT I), Hazardous Material Identification and Material Safety Data.

(vii) Any information requested by 52.212-3{f), Offeror Representations and Certifications-Commercial Items, that may be necessary to assure compliance with FAR 52.225-1, Buy American Act-Balance of Payments Programs-Supplies.

(2) Deletions. The Contractor shall provide an explanation for the deletion. The Government reserves the right to reject any subsequent offer of the same item or a substantially equal item at a higher price during the same contract period, if the contracting officer finds the higher price to be unreasonable when compared with the deleted item.

{3) Price Reduction[s]. The Contractor shall indicate whether the price reduction falls under the item {i), (ii), or {iii) of paragraph (cX1) of the Price Reductions clause at 552.238-75. If the price reduction falls under item (i), the Contractor shall submit a copy of the dated commercial price list. If the price reduction falls under item (ii) or (iii), the Contractor shall submit a copy of the applicable price list{s), bulletins or letters or customer agreements which outline the effective date, duration, terms and conditions of the price reduction.

{c) Effective d[D]ates. The effective date of any modification is the date specified in the modification, except as otherwise provided in the Price Reductions clause at 552.238-75.

(d) E!eelFORiG fl!e Updates [Electronic Updates to the Authorized Federal Supply Schedule (FSS) Price List. eMod will capture modifications and automatically update the contractor's Authorized FSS Price List on GSA Advantage! upon execution of the modification.] Tho Contractor shall update electronic file submissions to Feflest all modifications. For additional items or SINs, the Contractor shall obtain the Contracting Officer's approval before transmitting changes. Contract modifications will not be made effective until the Go¥omment receives tho electronic file updates. The Contractor may transmit price reductions, item deletions, and corrections without prior approval. However, the Contractor shall notify tho Contrasting Officer as set forth in the Price Reductions clause at 552.238 75.

(e) AmeRdmeRls to Paper Federal S(;Jpp!y SG/:lefh.lle Prise Lists. ( 1) The Contractor must provide supplements to its paper price lists, reflecting

the most current changes. The Contractor may either: (i) Distribute a supplemental paper Federal Supply Schedule Price List

within 15 workdays after the effective date of each modification.

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(ii) Distribute quarterly cumulative supplements. The period covered by a cumulative supplement is at the discretion of the Contractor, but may not exceed three calendar months from the effective date of the earliest modification. For example, if the flrst modification occurs in February, the quarterly supplement must cover February April, and every three month period after. The Contractor must distribute each quarterly cumulative supplement within 15 workdays from the last day of tho calendar quarter.

(2) At a minimum, the Contractor shall distribute each supplement to those ordering activities that previously recei•1ed the basic document. In addition, the Contractor shall submit two copies of each supplement to the Contracting Officer and one copy to tho FSS Schedule Information Center.

(f[e]) Electronic submission of modification requests [via eMod] is mandatory via eMod (http://eOffer.gsa.gov). URtess otherwise stated in the electronic submission standards and requirements at the Vendor Support Center website (http:J!vsc.gsa.gov). If the electronic submissions standards and requirements information is updated at the Vendor Support Center website, Contractors will be notified prior to the effective date of the change.

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MEMORANDUM FOR

FROM.

SUBJECT

PROBLEM STATEMENT:

GSA Fedora! Acquisition Servico

JEFFREY A. KOSES SENIOR PROCUREMENT EXECUTIVE (SPE) OFFICE OF ACQUISITION POLICY (MV)

CHIARAA. MCDOWELLCAci0>-1vtl fJ1cJ,J 1r/1/7t:tt,

DEPUTY ASSISTANT COMMISSIONER OFFICE OF ACQUISITION MANAGEMENT (QV)

Request for GSAR Class Deviations in Support of Competitive Pricing Initiative/Formatted Product Tool

The Federal Acquisition Service (FAS) requests a deviation from the following provisions and clauses to remove/update outdated language regarding the separate electronic submission of price list data and paper price lists to allow implementation of the Formatted Product Tool (FPT) within eOffer/eMod (see Attachment 1 for recommended language):

1. 552.211 -78 Commercial Delivery Schedule (Multiple Award Schedule} 1

2. 552.216-70 Economic Price Adjustment - FSS Multiple Award Schedule Contracts 3. 552.238-71 Submission and Distribution of Authorized FSS Schedule Pricelists 4. 552.238-72 Identification of Products that have Environmental Attrrbutes 5. 552.238-81 Modification (Federal Supply Schedule)

JUSTIFICATION:

The following information is provided to better explain how the requested class deviations will benefit the General Services Administration (GSA), FAS, and the Federal Supply Schedule (FSS) program

Concrete examples of past history under the current policy, with a description of the effect on the organization

1 This dause will be incorporated into General Services Administration Acquisition Regulation (GSAR) Subpart 538 and renumbered from 552.211-78 to 552.238-89 upon publication of the final rule under GSAR Case 2013-G502 Federal Supply Schedule Contracting (Administrative Changes).

U .S. Gen&ral Serv1co Admin1 \ration 1800 F S1reet NW Wash1ng1on DC 20405--0002 wwv gsagov

Currently, when a vendor submits an offer or a modification to a current contract under the FSS program, the price list is provided to the FSS contracting officer (CO) to negotiate and approve. This price list is usually provided electronically due to the convenience and time saving aspects of electronic submissions. After the contract is awarded or the modification is approved, the vendor must duplicate the price list submission by uploading their approved prfce list into GSA Advantage! through either the Schedules Input Program (SIP), either by an Excel template or directly in SIP. or through an Electronic Data Interchange (EDI) process. This requires the vendor to input additional information that may or may not have been in the original price list submission to the FSS CO, thus requiring the vendor additional time and money to ensure the price list is complete, accurate, and current. This is especially burdensome on small businesses that are manufacturers or resellers of large product lists, as the quality control can be extensive. A paper price list must additionally be submitted to further the duplicative actions.

This process is also cumbersome and confusing as it accounts for over 42% (23,000) of the calls to the Vendor Support Center Helpdesk every year. The FSS CO reviews the duplicate price list in the Contracting Officer Review System (CORS) to match this to the original submitted price list, which can take additional time and inhibit time to market for the vendor to start the first and easiest way to sell products and market its FSS contract. Also, as the vendor determines what information is to be put in the upload template for GSA Advantage! this data is not cleaned, thus part numbers. country of origin, and unit of purchase vary greatly, making it difficult for customers to purchase from GSA Advantage!.

Proposed advantages of the new policy

This effort it crucial to both the success of the FSS program and its ability to dehver to our customers and industry partners a best-in-class solution poised for growth, adaptability, and competition within the Federal marketplace.

• FPT is a data analytics tool that utilizes standardized part number data to automate price comparisons for like items. FPT will automate the submission of a vendor's product catalog under the FSS program, electronically capturing this information in a consistent. standardized format for both offers and modifications

• FPT will eliminate the need for SIP and CORS, removing a burdensome and duplicative process for vendors and FSS cos

• Instantaneous FSS price list availability eliminates delays between time of award/modification and customer access to items on GSA Advantage!, which means that new technologies can get to market faster

• Automated FSS price lists will eliminate inconsistencies between the items/pricing awarded under the contract and what is posted on GSA Advantage!

• Current and accurate FSS price llsts that include all awarded items means increased competition and more choices for customers

• Collection of formatted data and flagging of outlier pricing will provide horizontal price comparison data that will allow FSS cos to spend time more efficiently in terms of where they need to negotiate. cutting down on open market research and making the entire negotiation process more efficient

• In an effort to help vendors be as competitive as possible, GSA will share information with them on how their prices compare with other vendors offering the same items - this will be especially helpful to small businesses, which often do not have the resources to conduct such an extensive analysis

• Vendors can take this information into consideration when setting or adjusting prices to make items more competitive and/or remove items that are no longer offered/part of their business plan

• Increased customer faith in FSS program pricing increases the use of the program, which means increased sales for vendors and the potential for a reduction in contract duplication

• Standardized part number data will allow for the categorization of products in GSA Advantage! when customers are shopping - this can increase the likelihood that a customer will see and select a vendor's item

Current cost/benefit analysis (e.g., on market conditions/industry trends)

Currently, FAS receives and evaluates approximately 5,500 new offers, and processes over 27,000 contract modifications each year. Streamlining the FSS program's offer and modification requirements via the FPT is critical to helping FAS more effectively manage its enormous workload and timely provide FSS offerings to customers.

During Fiscal Year (FY) 2015, FAS coordinated a voluntary Competitive Pricing Initiative (CPI) pilot that involved 1, 750 FSS program contracts. Vendors were contacted based on an early version of the FPT that was able to identify awarded products with "outlier" pricing, i.e .. they were flagged because they fell outside of a designated range of price variability, appearing unusually high in comparison to identical products offered by other FSS program vendors. Collectively, these 1,750 vendors had nearly 2.5 million awarded outlier products under their FSS contracts. These vendors were provided with the FPT data and given an opportunity to offer voluntary price reductions to bring their pricing more in line with FSS program competitors. Nearly 1.4 million voluntary price reductions were attained during this pilot. Of the reduced items, 85% were brought within the target price ranges that were set. The median price reduction achieved was 20%.

1,;u~1v1111::1 1e:uu1111 r.::>.:> program pricing increases tne overan use of the program. which means increased sales for vendors.

• The data FPT provides will facilitate the award of better pricing, which will bolster confidence in the FSS program overall. Improved recognition of the value of the FSS program could lead to increased utilization, which would reduce ordering activity creation of duplicative contract vehicles. Reduced contract duplication removes barriers to entry into the Federal marketplace, especially for small businesses. The Government Accountability Office (GAO) reports the costs of being on multiple contract vehicles ranges from $10,000 to $1,000,000 due to increased bid and proposal, and administrative costs.

o Number of contractors affected In FY15, 16,529 contractors participated in the FSS program.

o Number of small businesses affected In FY15, approximately 13,800 small businesses (79% of total) participated in the FSS program.

<J Impact on small businesses {positive or negative) Better visibility of offered products, data that enhances a vendor's ability to offer competitive pricing, and added value that has the potential to increase the overall usage of the FSS program will all yield positive benefits for small businesses.

Potential impact on another Service

Not Applicable. This class deviation request only applies to the FSS program.

Opportunities for efficiency under the proposed change

FPT will work within the existing eOffer and eMod platforms to electronically capture a vendor's pricing information at the time of initial offer submission and/or modification request. eliminating the need for paper FSS program price lists as well as the SIP and CORS applications. FPT will automatically upload the vendor's pricing information to GSA Advantage! upon award of a contract and/or execution of a modification, thereby ensuring that this data remains as accurate, complete, and current as possible The pricing data that FPT collects will also lay the groundwork for the Transactional Data Reporting initiative (reference GSAR Case 2013-G504).

In addition, the added value FPT will bring to the FSS program and the related potential for reduced contract duplication that results will promote efficiency for all involved. GSA can focus its resources on improving the user experience under its contracts; vendors, especially small businesses, will have fewer contracts to manage, lowering therr administrative burden; and customers will have the ability to meet their mission needs through a less fragmented purchasing channel.

Analysis of alternatives, identifying risks and risk mitigation

The only alternative to pursuing class deviations was to open a GSAR case to permanently change these clauses and provis!ons. However, there are still multiple unknowns related to the FPT initiative and its implementation (e.g • the desired incorporation of services) and making these changes via class devlations in the short term will allow FAS more time to explore all opt.ans, to work out any issues that are identified as FPT is rolled out across the FSS program (systems. clause/provision wording, etc.), and to obtain feedback pnor to pursuing permanent changes via rule making.

The timing of the FPT launch may change based on other major FAS initiatives. Though the deviated provision and clause language in this request is intended for new offerers, FPT will heavily rely on the submission of "baseline" information from existing FSS program vendors. There are more than SO million products currently awarded, and the utihty of the FPT going forward will depend on existing vendors and their submission of standardized part number and other formatted data into the FPT itself. This will require a bilateral mass modification, the efforts of FSS COs to review and approve the data. and ongoing tracked compliance. As the Transactional Data Reporting initiative is also going to rely on this data, and the publication date of the final rule for Transactional Data Reporting remains relatively fluid at this time, FAS will be closely monitoring progress under related initiatives in order to ensure that efforts are sequenced in a way that has as little negative impact on the FAS workforce and FSS program vendors as possible.

There is a nsk related to change management for the process. To mitigate this risk, FAS will cont nue to make updates to the systems and have robust training and user feedback loops to ensure voices are heard. Further, the rollout schedule can be slowed if any large issues occur.

Any effects on automated systems (I.e., financial and procurement)

FPT is currently being built on the same platform as eOffer/eMod, thus connecting the offer and modification process with the GSA Advantage' upload This will eliminate the need for paper FSS program price lists as well as the SIP and CORS applications. The Electronic Centralized Acquisition Tool (eCAT) would need to be updated to reflect changes to solicitation provisions and clauses.

Proposed milestones for Initiation, Including training

FPT will be implemented on a rolling basis, beginning July 2016. The first rollout of FPT will occur under the following Schedules2

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Schedule Implementation Date 58 I - Professiona I AudioMdeo Telemetry/Tracking, 7/12/2016 Recording/Reproducing and Signal Data Solutions 72 - FumishinQS and Floor Coverinos 7/12/2016 51 V- Hardware Suoerstore 7/26/2016 75 - Office Products/Supplies and 8/23/2016 Services and New Products/Technoloov 73 - Food Service, Hospitality, Cleaning Equipment and Supplies, Chemicals and 9/6/2016 Services 70 - General Purpose Commercial Information Technology Equipment. 9/6/2016 Software, and Services Remainino Schedules Fiscal Year 2017

Once the class deviation is approved, FAS will provide 30-day advance notice to vendors via GSA Interact regarding the draft significant changes that will be included in the solicitation refreshes and mass modifications, prior to their official release. In addition to this notice, FAS will host a vendor webinar lo provide a forum lo discuss these changes, providing an opportunity for communication between GSA and industry before implementation.

Currently, as contractor price lists are considered to be fair and reasonable, FSS COs will concentrate on first moving contractors to FPT. Over the next year, FSS COs will work with their vendors to rebaseline pricing where needed to ensure vendors are within a competitive range to be successful within the FSS program. As price lists are modified, the FSS CO will ensure the proper modification documentations are completed by all parties through eMod.

As with all changes within the program, FAS will work with contractors to help understand the importance of accepting the modification and the benefits to the FSS program.

Policy guidance and internal/external training will be provided to coincide with the implementation schedule. Training will be completed through live and recorded

= Implementation details and timing arc subject to change bued on programmatic nei:ds and the discretion of FAS lcadcr~hip Any such changes will be separately communicated to ponfolio representatives and solicitation owners Future FPT enhancements will include accommodations for services pricing that will allow for implementation across all Schedules.

webinars and training modules specific to the system. Industry will also have access to a robust user guide with step~by-step instructions.

FAS intends to complete efforts to implement FPT across the FSS program - to include all Schedules, both products and services - by the end of FY 2017. At that point the SIP process wll! be removed as an option, therefore contractors must sign the mass modificatron in order for their price list to be posted on GSA Advantage! for any future modifications as to keep their price list competitive and current.

Approach to monitoring success and determining whether or not the deviation will continue

The key measure of success will be feedback from FSS COs, ordering agencies, and vendors. Achieved price reductions will be monitored, as will any changes to overall FSS program sales and business volume.

FAS wilt also monitor the helpdesk volume as related to price lists, in both original offers and modifications.

Any FSSI team interaction or recommendation should be Included to support the overall strategic sourcing goals being sought

None

RECOMMENDED LANGUAGE:

See Attachment 1 for recommended language.

PREPARED BY:

Denise E. Alley Procurement Analyst (QVODA) Phone: 703-605-2756 Email: denise alley@gsa.gov

SENIOR PROCUREMENT EXECUTIVE REVIEW;

Approved:------------

Date: --------