Agency seeks comments on modular contracting

The General Services Administration is soliciting comments on a white paper designed to offer federal agencies detailed guidance on how to conduct modular contracting.

Lawrence Wolfe deputy associate administrator for information technology in GSA's Office of Governmentwide Policy said the white paper will help agencies comply with the section of the Clinger-Cohen Act that requires agencies to purchase large IT systems in increments or modules rather than all at once as in the past. The Office of Management and Budget views modular contracting as one of the key elements in improving procurement because it gives agencies the ability to contain cost and schedule overruns without enduring multiple costly procurements.

Wolfe said the white paper issued late last month was circulated to federal procurement personnel and interested private-sector organizations.

"Modular contracting is a very hot topic right now " Wolfe said. "Congress has urged agencies to use modular contracting for their largest acquisitions but there is really no guidance out there to help them do that. The purpose of this white paper is to get guidance out there quickly."

Addressing Specific Concerns

Walter Cate chief of information systems acquisition at the State Department and a member of the interagency committee developing the IT portion of the Federal Acquisition Regulation said he believes the white paper will supplement guidance provided in the FAR which deals with modular contracting only in general terms.

"When the FAR IT committee looked at writing regulations we discussed the extent to which we should go into detail " Cate said. "We came to the conclusion that the regulation should discuss modular contracting at a very high level and the specifics should be addressed in several nonregulatory documents. I think this white paper is an example of that."

Cate added that the white paper also may help the government address some concerns and questions submitted by industry when the proposed rule for modular contracting was issued last year. "The proposed rule generated a number of public comments a lot of which were from industry " he said. "They indicated that there would be questions raised when agencies tried to implement this and that additional guidance would be useful."

Olga Grkavac vice president of the Information Technology Association of America's Systems Integration Division said she had not yet had time to thoroughly review the white paper. But she added that ITAA was interested in the issue and would submit comments to GSA.

Setting Standards

Cate said concerns about modular contracting focus mainly on integration and interoperability. The white paper addresses questions such as how agencies can ensure that modules developed by different contractors - and even those developed by the same contractors - will integrate as they are deployed. It also discusses ways for agencies to adopt standards to create an agencywide architecture that will facilitate interoperability between modules.

Wolfe stressed that the white paper is not a finished product and is merely a stepping stone toward a more detailed modular contracting acquisition guide expected early next year. He said he hopes to incorporate agencies' comments and lessons learned into the final version.

"We're interested in agencies' experiences implementing modular contracting or if they have techniques that have or haven't worked in the past " he said.

Cates said few agencies have yet to delve into modular contracting "on a broad basis." But he said GSA's guidance will be a valuable source of information to them as they begin to move in that direction.