GSA SEEKS FAIR AND REASONABLE PRICING INPUT

Industry should never pass up an opportunity to let the government know what’s on its mind, especially when the government asks for it.  Such is the case now that GSA is seeking input from Schedule contractors on how it determines fair and reasonable pricing on Schedule contracts.  Many contractors know that documenting fair and reasonable pricing to Schedule contracting officers has become a difficult challenge in a time of inflation.  Some CO’s appear to try and wait out changes in commercial pricing indexes, hoping that they will decline, so that they don’t have to improve price increases.  Others ask for extensive commercial pricing information to ensure that there is more than enough documentation for even the most routine pricing matters.  On the policy side, GSA is seeking a statutory change to the Competition in Contracting Act (CICA) that would allow Schedule buys to meet CICA standards when they offer “fair and reasonable” pricing, rather than the current language stating that Schedule contract buys must represent “the lowest overall cost alternative” to the federal government.  Both actions mean that ensuring the term “fair and reasonable” is properly defined and understood is of particular importance right now.  GSA is conducting market research to obtain a better definition and provide guidance to contracting officials on how fair and reasonable pricing should be determined moving forward.  The “MAS Pricing – Market Research” Request for Information (RFI) is the main way for industry to submit comments on this front.  All Schedule contractors should take time out to ensure that their views on this matter are known to GSA.  While industry may not get all that it wants from GSA’s exercise, companies essentially forfeit at least some claims to unfairness if they fail to make their voices heard.  Comments on the RFI are due May 8th. The link to the RFI is here:     https://feedback.gsa.gov/jfe/form/SV_086qrHxkHL2u9dc.  It’s time to get writing!