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Mentioning the expense of upgrading its data systems, GSA is proposing to ask suppliers to report to GSA the information of what was bought through GSA. This is like asking merchants selling through Amazon to report to Amazon what it offered, through Amazon. GSA SER. To take this example one step even more, Amazon would then use that details to market pricing to other customers, on Amazon.

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While not a perfect comparison, GSA in many ways operates as an Amazon-like part of the acquisition procedure. Asia Virtual Solutions. The intent behind this rule is seeking to make a best-in-class contracting market. GSA has actually decided to pass on investing in a data collection system that might gather this information automatically.

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II (GSA SER). The Rule Enforces a Considerable, Underestimated, and Unnecessary Problem GSA approximates that it will take six hours for a contractor to achieve all tasks needed to understand the reporting requirements, prepare its systems and workers, and develop the procedures required for creating the needed reports, and a typical 31 minutes each month for continuous reporting. Asia Virtual Solutions. 2 GSA does not offer sufficient detail to evaluate how these quotes are flawed, however virtually every informed party who has actually weighed in on these quotes believes they are inaccurate.

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Reg. 11625. GSA SER.

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Otherwise, the contractor will risk an allegation of fraud under the False Claims Act, as has held true with essentially every other type of price or expense reports sent by a contractor to the government. Notably for this hearing, small companies will bear the largest part of this burden-- GSA approximated that out of 15,738 suppliers holding contracts that would be subject to this Guideline, 12,590 are small companies. GSA Search Engine Ranker Services.

Reg. 8 GSA likewise recognizes a point very essential to industry-- that rate paid is only of many "information points"in determining the finest worth to the government. 10 We can also include client service, product assistance services, warranty, and other terms to this list.

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According to GSA's own analysis, this concern imposed on specialists will offer the government with only one of the necessary details points-- transactional cost-- without any means to acquire the other details points required to evaluate price (GSA SER Software). Without access to, and factor to consider of, this other crucial information, the cost details is of little value at finest and can be really deceptive at worst.

In my view, the inability of the Guideline to capture these other non-price factors might be specifically hazardous to little services. Small businesses often run as value-added resellers or otherwise distinguish themselves in the competitive market based upon the worth they contribute to a transaction, such as client and item service capability, that is not captured by transaction rate.

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