It’s time again to dust off my soap box. If you’ve followed my Reporter’s Notebook over the last decade, you know there is nothing I find more frustrating than when agencies put acquisition documents, particularly requests for information, behind the firewall of the General Services Administration schedule/eBuy/GSA Advantage!
If the idea is to get feedback and expose these ideas and concepts to the widest audience possible, then limiting who can actually see and respond makes no sense to me. I know there are folks out there who disagree with me and could make a somewhat sensible argument as to why agencies do this, saying its part of the benefit of getting on the GSA Schedule in the first place.
But with all the talk about expanding the industrial base, reducing burdens on contractors who want to work with the government and increasing transparency of the acquisition process, opening up these platforms for “read only” privileges to everyone would be an easy “win” for the Office of Federal Procurement Policy and GSA acquisition leaders.
So as I blow the dust off my soap box and I step up to explain, once again, why I’m calling on federal leaders, this time OFPP Administrator Kevin Rhodes and GSA Senior Procurement Executive Jeff Koses, to “tear down the wall” that surrounds the schedule, eBuy and GSA Advantage.
GSA issued two RFIs recently, both of which deserved more attention.
One was for the Second Generation IT (2GIT) follow-on contract. The other was an RFI and draft solicitation for a new blanket purchase agreement from the Technology Transformation Services called Next Generation IT Services (NEXT).
Thanks to friends in industry, I obtained a copy of both RFIs and assorted documents and will offer a few highlights.
Let’s start with TTS’s NEXT program since there still is time to respond to that RFI. Responses are due Feb. 17, so get moving.
“GSA’s Technology Transformation Services (TTS) Technology Acquisition Division (TechAcq) seeks to establish approximately six BPAs to support enterprise-level information technology services across multiple support areas. The BPAs will provide flexible, scalable, and outcome-based IT solutions supporting evolving mission needs,” the RFI states. “Although each BPA will have its own defined support area description, the government’s intent is to allow flexibility in the support areas at the BPA and call order level.”
GSA’s initial thinking is that it will have one BPA for each service area:
- DevSecOps and secure modern development
- Digital services, and experience design and delivery
- Cloud, infrastructure and cybersecurity services
- Identity verification and entity validation support
- Fraud detection and threat mitigation services
- Artificial intelligence strategy and implementation
In each service area, GSA lays out the purpose of the BPA, key services covered and why it matters.
One big question GSA is asking in this RFI is if there are existing contract vehicles that already cover some or all of these services.
“TTS anticipates establishing approximately six BPAs, with on and off-ramping, to support enterprise-level information technology services across multiple support areas. This market research effort is being conducted on GSA eBuy for GSA MAS, the GSA Alliant 2 GWAC, and the 8(a) STARS III GWAC,” the RFI states. “In addition to the potential six BPAs being considered for GSA MAS, Alliant 2, and 8(a) STARS III, the government is considering open-market actions for Support Area 5 (fraud detection and threat mitigation services) and Support Area 6 (AI strategy and implementation). The government is interested in the ability to make quick, low-dollar value awards using innovative techniques and is interested in reaching new technology companies, start-ups, etc. A separate market research effort for these actions will be conducted on SAM.gov at a later date.”
GSA took a similar approach with the 2GIT II RFI, opening it up only for current contractors on the IT services contract.
Public debate on the transparency question
Interestingly, I posted this question about why not make the 2GIT II RFI public on LinkedIn, and the small community of respondents were mixed but thoughtful on GSA’s decision.
Nic Chaillan, the founder of AskSage and former Air Force and Space Force chief software officer, was among the more cynical of the respondents in explaining why the RFI was behind the firewall: “Usual shenanigans to rig bids.”
Trevor Wagner, the director of The LAB at the Commerce Department, which is an initiative to bring acquisition innovations to the agency, was more pragmatic.
“I’ll provide two answers: 1) Should this RFI be posted to SAM, 2) Must it be posted to SAM. 1) I often recommend casting a wide net during Market Research, and SAM is the best place for that as the official GPE. From there, you can further assess which GWACs or FSSs the seemingly capable vendors have. You also send the signal that you are open to solutions and competition, even if later you send a more targeted RFI or other engagements with industry purely via eBuy as the communication channel. 2) No. This is an RFI not a presolicitation notice, it is not a proposed contract action. An RFI is just one tool to consider for good market research. The team may already understand, especially with the commercial first push and centralization to GSA MAS, that they have more than enough capable vendors with an FSS – thus eBuy makes sense.”
In the RFI, GSA says the 2GIT II BPA will provide “commercial off the shelf (COTS) IT products (IT hardware and related IT software products, commercial support services, and ancillary services) in support of government agencies and their missions.”
Among the questions GSA asked is whether a potential bidder is a value-added IT reseller (IT VAR) or an original equipment manufacturer (OEM), how the bidders would align with GSA’s OneGov principles, such as providing savings and discounts off current schedule prices and for how long those savings/discounts would be in place.
Responses to the 2GIT II RFI closed on Jan. 30.
I’d be remiss if I didn’t recognize GSA tested out the idea of opening up eBuy more broadly back in 2019. The Open eBuy pilot published statements of work after award using e-Buy as a way to make it easier for non-schedule holders to better understand what agencies are buying from the schedule. The unfortunate truth about that pilot is no other agencies outside of GSA participated and it quietly ended in 2020.
But with all the changes OFPP and GSA are leading with the overhaul of the Federal Acquisition Regulation, now is the perfect time to open up eBuy. It doesn’t have to be in regulation, but why not in policy? And with all the workforce changes, many of the old guard acquisition leaders who blamed lawyers as the reason why eBuy needed to remain behind the firewall have left government, thus reducing some of the systemic culture blockers. That, combined with the current environment of updating acquisition process, indicates there is no better time than today to “tear down that wall.”
Acquisition workforce updates
Speaking of the acquisition workforce, OFPP is lowering the education requirements for contracting officers and others who fall under the Federal Acquisition Certification in Contracting (FAC-C) professional category.
“Based on feedback received from the acquisition community, OFPP is revising the required continuous learning points needed for FAC-C (Professional) to 80 CLPs every two years. This change is effective immediately for the current and future common periods,” OFPP stated in a new memo posted on FAI.gov. “There is no change to FAC-COR or FAC P/PM continuous learning requirements.”
OFPP set the number of continuous learning hours at 100 in 2023 as part of an update to bring the entire federal government — Defense and civilian agencies — under one education and training standard for contracting officers.
Additionally, OFPP lays out opportunities for contracting officers to obtain new training on the changes detailed in the FAR overhaul.
The changes to the education requirements are driving several of OFPP Administrator Rhodes’ top priorities in 2026.
In a separate memo sent out Jan. 23, Rhodes wrote that all the change in the acquisition community over the past year is about enabling employees to deliver results faster, better and cheaper.
“For decades, acquisition professionals were asked to move faster, reduce costs, and increase competition – while operating inside a system that too often worked against those objectives,” he wrote. “By removing regulations that added cost and time without value, and by pairing those changes with clear top cover from senior leadership, we are restoring the proper balance between statutory guardrails and professional discretion.”
The next steps across each of Rhodes’ three priorities include:
- Speeding acquisition: Completing phase 2 of the FAR overhaul, which includes finalizing the FAR rules. “We will ensure our ‘default behavior’ is to consolidate procurement whenever we can to avoid the wasted time and effort of duplicative contracting on the open market. We will responsibility deploy AI to enhance – not replace – professional expertise, and modernize acquisition systems so they support sound decision making.”
- Reducing costs: Rhodes said OFPP will refresh and strengthen federal category management efforts to use existing GWACs and buy commercial products.
- Increasing competition: Rhodes said the focus for agencies is to move toward outcome-based approaches rather than prescriptive requirements.
“Our culture depends on strong, clear and purposeful communication. Leaders must create defined lines of responsibility and expectations for success,” Rhodes wrote. “I will continue to push for you as practitioners to have the ability to remove barriers, share insights across the stakeholder sphere and engage openly with industry. Across the enterprise, we will maintain dialogue up and down as well as outward, ensuring the system works for those who use it. This is how we will sustain reform and keep the system aligned with mission reality.”
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