Advocacy Group Asks Biden Administration to Consider 7 Reforms for Governmentwide Contracts

The Biden administration—like the Trump and Obama presidencies before it—is pushing agencies to use large preestablished contract vehicles like the governmentwide acquisition contract, or GWACs. But while these procurement vehicles create stability in the federal market, they are limiting competition among certain sets of innovative companies, according to a letter sent to the administration and GWAC managers Tuesday.

A white paper penned by the Alliance for Digital Innovation was sent to the White House, Office of Management and Budget and contract managers at the General Services Administration—which manages several GWACs including 8(a) STARS, Alliant and VETS—NASA—which manages the Solutions for Enterprisewide Procurement, or SEWP, GWAC—and the National Institutes of Health—which houses the NIH Information Technology Acquisition and Assessment Center, or NITAAC, and its three GWACs: CIO-CS, CIO-SP3 and CIO-SP3 Small Business, with the latter contracts about to enter their fourth generation.

In the white paper, ADI’s membership—which includes big names like Adobe, Amazon Web Services, Google Cloud, Palantir and Salesforce, among others—point to issues with how GWACs are established and competed and offer seven recommendations members claim will help innovative companies sell their solutions to agencies in need.

While GWACs were established to offer a stable set of buying options, most are working to incorporate innovative and cutting-edge technologies, including those not yet on the market. But, according to Matthew Cornelius, executive director of ADI, the vehicles aren’t properly set up for this.

“In theory, the GWACs create a large and well-defined pool of capabilities that agencies can easily buy; however, the administration of GWACs have led to these vehicles restricting key evaluation criteria for GWAC competitors, creating barriers to entry for new market entrants over the course of the contract lifecycle, and forcing innovative companies to weaken their unique attributes by forcing them into teaming arrangements or joint ventures,” the white paper states. “Because of these decisions, the GWAC universe has significantly restricted agency efforts to accelerate IT modernization, digital transformation, and rapid identification and mitigation of ever evolving cybersecurity threats.”

Cornelius said the process has created “commoditization and harmonization,” which has, in effect, limited the degree to which small and medium sized businesses and non-traditional vendors can compete for that business.

“Sure, there’s still a need for common, commoditized buys in the product and service space,” he told Nextgov. “But there’s so much more innovation happening in industry that these are, in our opinion, a useful set of vehicles that can both help non-traditional businesses move into the federal government faster and get the scale and visibility and customer access—and understanding—versus just going on the [GSA] Schedules and competing against thousands and thousands of other vendors.”

The white paper offers seven recommendations for improving the GWAC ecosystem:

• Focus on the most relevant evaluation criteria, advocating in the letter for a “show, don’t tell” method to demonstrate useful solutions, rather than relying on traditional metrics like company size and past performance.
• Reduce administrative burdens, including requiring unnecessary accounting procedures and third-party certifications like the Capability Maturity Model Integration. The letter also warns against moving forward with “requirements that are not ‘fully baked,’” citing the Defense Department’s Cybersecurity Maturity Model Certification.
• Expand industry engagement, particularly with vendors new to the federal contracting space.
• Leverage commercial use cases and give those greater weight than past performance on federal contracts.
• Improve onboarding and offboarding to bring on a continuous stream of innovative solutions as new offerings and hew legacy and underperforming vendors to eliminate clutter.
• Create training programs to support new entrants, similar to GSA’s FedRAMP Ready program, which helps vendors get started with the process of applying for a provisional authority to operate.
• Revise the philosophy of teaming agreements and joint ventures to better serve medium-sized vendors and not penalize companies for not teaming.

Cornelius said that while the letter is speaking on behalf of ADI’s members, the same sentiments have also been heard from federal GWAC managers at GSA, NASA and NIH.

“This paper is not just ADI’s ideas—not just something we thought of ourselves. We’re hearing it from the folks who are managing these GWACs and they’re saying, ‘We feel like we’ve moved too far into this streamlining and commoditized situation,’” he said. “‘To stay competitive, our customers need access to a new set of capabilities. What can we do?’ they’re asking us.”

Cornelius said the white paper’s goal is to offer “practical and useful,” iterative changes that GWAC managers can implement over time to improve the vehicles. ADI’s members are not specifically looking for major policy changes from OMB at this time, he said.

“Based on numerous conversations that our members individually and ADI as an organization are having with folks in the GWAC policy and administration space, this paper is a recognition of some of the challenges they’re hearing and our ways to say, ‘Here’s what you can do to help scratch that itch,’” he said.

He pointed to the recommendation to improve onboarding and offboarding as a prime example.

“A lot of these companies … if they’re not in on Day 1 for a lot of these GWACs, they’re never getting on,” he said. “If you don’t hit that evaluation criteria up front, you’re not there, you’re locked out for forever.”

Cornelius noted there are reasons for GWACs being set up this way. But ADI is asking for some incremental changes to enable more competition from vendors that feel shut out of the process.

“This is not big picture, major FAR changes, policy stuff,” he said. “This is: What are the current impediments to getting better, smarter, innovative companies into the federal ecosystem.”

When prompted, Cornelius noted there are options for innovative small and non-traditional businesses, including the use of other transaction authorities; small business innovation research and small business technology transfer, or SBIR/STTR, programs; and assisted acquisition shops like GSA’s Technology Transformation Services. However, these programs aren’t always suited to small traditional contractors and medium-sized businesses.

Cornelius said ADI hopes GWAC managers will consider these recommendations, especially for vehicles that are in the solicitation phase.

“For us, what success looks like for ADI—and, more importantly, what success is going to look like for those agency customers—is things like [NIH’s CIO-SP4] and GSA’s Polaris and all the other GWACs that are going through the process right now, that they take some of these recommendations and make them a part of the foundation of how they’re managing those large contracts,” he said, adding that he hopes over time those will “bubble up” to conversations at OMB and the Office of Federal Procurement Policy.