A new GSA Office of the Inspector General report reviewing the agency’s oversight of performance-based contracts found:

“…while the Federal Acquisition Service has established an internal policy intended to improve contract administration, the policy’s effectiveness could not be determined because Federal Acquisition Service contracting personnel were not complying with the policy.”

This statement could actually have been written about a variety of GSA policies.  It points up a larger problem that GSA contractors face every day:  the disconnect between what a policy says and how it is actually implemented.  Anecdotal evidence supports the IG’s performance-based contracting findings and suggests that some GSA contracting personnel do not always follow policy directives and the flexibilities built into them.  The most recent example of this is GSA guidance enabling contracting officials to grant inflation-based price increases higher than those typically allowed on a GSA Schedule contract.  The policy is flexible and meant to ease the strain inflation has put on companies, especially smaller firms.  Ask those small businesses whether they were able to get a needed price increase, and how easy it was to obtain one if they were successful, and you’ll likely hear a story that is something different from what the policy intended.  Schedule contract specialists also routinely insist on the best price a contractor has in order for that company to obtain a contract, even though the policy says that obtaining the best price is only the “objective”.  There is no value in a contract with a price that is unrealistically low.  Years ago the GSA IG took a dim view of how the then-Federal Supply Service combined its operations and policy components.  Those operations have now been segmented.  One impact is that it is now more difficult to effectively manage the FAS acquisition workforce.  As the report shows, contracting personnel don’t always follow policies and guidance, often resulting in program outputs that are quite different from what was envisioned.  This creates frustration for contractors and GSA customers.  The IG performance-based contracting report recommends more training.  That’s a good place to start tactically, but GSA officials should work to develop a solution at the strategic level.