The Cancellation Heard ‘Round the Beltway: A2SB

Tuesday, July 28, 2020

The General Services Administration (GSA) sent a shot around the Government Contracting universe just a few short weeks ago. After a five-plus year procurement timeline, 493 bids submitted, and over 15 protests – GSA canceled the highly anticipated Alliant 2 Small Business (A2SB) Governmentwide Acquisition Contract (GWAC) and pissed all of us off. 

Following the cancelation of A2SB, GSA’s Assistant Commissioner for the Office of Information Technology Category, Laura Stanton, released a blog post mentioning that they plan on conducting a wholesale reevaluation of their socio-economic vehicles. As with any large vehicle news, industry conducted its post-mortem – but a lot of the conversation focused on what GSA did wrong and where the agency should go from here…sans any real input on what is realistic for actual Government Contractors. 

This type of earth-shattering cancellation is not uncommon in our industry, and not just for GSA. However, this particular cancellation is timely as it is littered with complexities that will have major consequences for small-and mid-tier Government Contractors hoping to keep their organizations competitive over the next year. Long-lasting, impactful initiatives are at play here ranging from Cybersecurity Maturity Model Certification (CMMC) to Category Management/Best-In-Class (BIC) contracts to GSA eBuy Multiple Award Schedule (MAS) consolidations

To be frank, GSA has dropped small-and mid-tier Government contractors out into the middle of the ocean without a life raft and the water is turbulent. 

The A2SB cancellation has made The Pulse of GovCon mad as hell. We want to make sure the industry understands why this is detrimental to our ecosystem. To help us speak to this more eloquently, The Pulse reached out to Courtney Fairchild, President, and CEO of Global Services, to discuss the impacts and realities of the A2SB cancellation.

Why is the fall of A2SB detrimental to our industry?

The original capture behind A2SB was expensive enough. Because of the BIC classification, small businesses competing in the IT NAICS were clamoring to obtain this vehicle. Many did so in pursuit of a specific opportunity or two that were set to have competed under the A2SB GWAC and many lost access to those opportunities since this procurement failed.  

To recap, A2SB was first awarded to 81 bidders in February 2018, but after another year of protests that were upheld, the awards were pulled back, and ultimately the procurement was canceled over this long five-plus year procurement timeline from start to cancellation. Sadly, the cost of running capture on this opportunity over the elongated period while adding in the lost bids is more than any small business should reasonably be expected to spend.

I fear that GSA may be losing trust with both industry and government buyers over botched procurements like this. Sometimes a contract vehicle is only as good as the confidence you have in the agency that runs it for both pursuits by industry and use by the agencies.

What might be more problematic in terms of faith in the vehicle is that the procurement process of A2SB lacked any sort of transparency and real communication. I sincerely believe that the bidders deserved to understand what was happening through those years and even more now. What is stopping GSA from explaining the issues with the protests and to further detail what their intentions of issuing a different type of A2SB will look like? The veil of secrecy is not doing anything to help contractors or ordering agencies that want to bid on or utilize the resulting contract.

We have seen a lot of talking heads recommend GSA take the MAS approach. What would be the pros/cons of this?

I am going to assume you mean letting everyone minimally qualified onto the vehicle and letting them fight it out at the task order level. I think there is some value in not shutting out all types of small businesses from a significant procurement and giving customers many options from which to choose. However, the devil is in the details of how those task order competitions would run under the vehicle. I know that evaluating hundreds or thousands of bids is exactly what busy procurement staff would like to avoid when issuing a task order under an existing vehicle. 

If it is not easier than a full and open competition, why create the contract vehicle? 

No one wants less competition or access for a small business, but the reality of the overworked buyers in these positions is real. GSA must be careful not to make it so hard to use that agencies don’t want to use the vehicle in the first place. The other issue is the low bar of entry. Knowing how low the bar is could create an additional lack of confidence in the pool of awardees and drive work to other vehicles instead.

(Pulse Note: With CMMC being a factor now, it would be difficult for GSA to lower the bar for consideration. Additionally, an approach like Seaport-NexGen would not be possible as Seaport-NexGen is a MAS Indefinite Delivery/Indefinite Quantity (IDIQ) meaning that only the U.S. Navy can use the vehicle. GSA’s main driver is to have external agencies use the vehicle, so a MAS IDIQ is out of the question.)

If GSA did go the MAS vehicle route – what would be the difference between that and their GSA schedules? Would it be duplicative?

There would be seemingly little difference I suppose. But a MAS vehicle route would offer potential set-aside tracks for Woman-Owned Small Businesses (WOSB) and Historically Under-utilized Business Zones (HUBZone) along with the ability to do Cost-Plus-Fixed-Fee (CPFF) contracting, which would be two big differences to start.

If there is little difference, why does GSA continue to create new vehicles when they have GSA eBuy Schedules?

There was a better reason for some vehicles like the One Acquisition Solution for Integrated Services (OASIS) GWAC rather than Alliant because it allows for CPFF contracting, which a GSA eBuy Schedules do not, and the U.S. Air Force was requesting this ability. 

Additionally, the idea behind OASIS (when used properly which is not always) is for the purchase of complex professional services that span more than one type of NAICS and run a multitude of subcontractors. In theory, it is a better justification for a different contract vehicle.  I do not believe that the Alliant GWAC is this type of differentiated vehicle but rather just another IT-focused GWAC in terms of scope.

What stands in the way of just modifying the GSA eBuy Schedules to encompass everything that is appealing about these BIC GWACs?

It would be a different procurement but doable. Could they not issue Blanket Purchase Awards (BPAs) to winners for A2SB but under the GSA Schedule specific Special Item Numbers (SINs)? It would take some tweaking to the categories but it would fall in line with Category Management and you could use the existing awardees as potential bidders. Because the GSA Schedules are always open and available there is a much lower barrier to entry than most other vehicles out there. The BPA does not have to be open but could start with a qualified set of potential bidders as well. The only glaring thing I would see missing is the ability to do CPFF work on Schedules.  

Since I started in this industry over 20 years ago we have been talking about competing vehicles. Should agencies create their own or use the vehicles that GSA has put out? GSA inventing vehicles to compete with themselves is a variation on the theme. In general, wouldn’t we be more efficient and perhaps leaner if we moved to fewer vehicles? But does that ultimately mean that the competition is lessened? It is dependent upon the structure of the vehicle as well as the rules for competition during use. I’m sure the answer is that there must be a balance.

So where do we go from here? Well, every action in Government Contracting has an equal and opposite reaction. The aftershock from the A2SB cancelation vibrates much further than the obvious areas and has left us with more questions than answers. A clean conclusion here would be ideal, but unrealistic. Instead, here are the questions on our mind that we propose to GSA to consider:

  • What now? What can previously A2SB awarded vendors do if they do not have access to a BIC vehicle now? Is it helpful to just make 8(a) STARS III open to all small businesses as subcontractors? What about OASIS and it’s a 10-year period of performance which allows small businesses to stay small even though revenue/profit-wise they are no longer?
  • Category Management? How badly will the absence of this vehicle impact Category Management?
  • FAR definition? At this point, not having a legal FAR definition of BIC vehicles is detrimental to the industry because right now, except for a few, the definition is that the vehicle is owned by GSA. With this cancelation, and the initiative to re-think GSA GWACs, would it be better for the industry to have an agency external to GSA define and select these vehicles?
  • CMMC? Under GSA GWACs, CMMC introduces a new need for more than just socio-economic tracks. There are Government Contracting vendors that choose not to pursue work with the Department of Defense. Will there be socio-economic and CMMC tracks on their GWACs now? Or will CMMC prove to be another critical Go/On-Go bid factor-like Cost Accounting certifications?

Nothing in the Government Contracting will change without open and honest dialogue. If you have comments or questions, then make them known! Contact us with the implications as you see them. 

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