OBITUARY: THE DEATH OF COMMERCIAL ITEM BUYING
Well, it was fun while it lasted. The heyday of commercial item acquisition and a “commercial first” approach to government acquisition is fairly well over. While products and solutions sold in the federal space may technically meet the definition of “commercial item” in that they in many ways look like items that are offered for commercial sale, or are services “of a type” that are sold commercially, each must meet an increasing number of federal unique standards. Do you want to do business with a government agency? Before you raise your hand, you must conduct a review of all of your company’s telecommunications solutions to ensure that they are Section 889B compliant, even if those systems have nothing to do with your government business. Want to sell cloud-based solutions? There’s a process for that – FedRAMP. It costs a tidy sum to have a commercial solution certified by a third-party, and that’s if you can find an agency willing to sponsor it. Handle Controlled Unclassified Information (CUI)? CMMC is coming soon, DOD promises, to a contract near you. That will require its own third-party certification process, adding to the cost of doing government business. These are just some examples of how commercial items must be either certified or modified to meet federal-unique requirements. All of them cost money for a company to comply with. Note to GSA Schedule contracting officers: You won’t be getting the lowest price because Schedule contractors don’t have to jump through so many flaming hoops to sell in the commercial sector. Your business is more expensive to conduct. It is no wonder that companies, particularly small businesses, leave the federal market in droves each year. Business becomes concentrated inside a realm of specialized companies that can take meet a seemingly ever-growing array of new rules. Even small businesses must be large enough and focused on the federal market in order to make compliance possible and worth the investment. Many of these issues are already widely recognized. There have even been previous attempts to exempt commercial item buys from every new rule. No more. An array of federal security standards and the proclivity towards making federal acquisition a testing ground for a host of socio-economic or other perceived goods abound. Competition suffers. Innovation suffers. Prices are higher. RIP Commercial Item Acquisition. Anyone remember Reinventing Government?