The new presidential administration is promoting “evidence-based”
decision making. Fair enough. Companies often use “data driven” models to
make critical business decisions. Data
is mined, sliced, diced, shredded and re-packaged to fit a host of analytical
needs, whether in procurement and contracting or in other operations. Precisely because it is good to know where
you’re going, though, it is imperative to know that data has its limits. As Texas Tech economics professor Andrew
William Salter recently said in The Wall Street Journal, “Data
doesn’t interpret itself.”
Further, people cannot “just let the data speak for itself.” A set of the same figures can be, and
often is, interpreted differently by people with differing perspectives,
preferences, or agendas. This is
nothing new, either. Mark Twain is
famous for his 19th century line, “There are lies, damn lies, and
then there are statistics.” Compiling
and analyzing data can be an important component of decision making, but it
should not substitute for the ability of experienced, educated people to make
their own final decisions. People using
the tools must be adept at it and, in our own Ikea experiences, some are just
better than others in so doing. Blindly
going where you think the data are directing you may, like a GPS system, result
in your going over a cliff.
Users of data need to understand its limitations and that, ultimately,
there must be sound interpretation of the data, and other inputs, before
decisions are made. Contractors
may have to make this point on procurement policy multiple times over the next
four years. Be prepared.
Although President Biden has nominated
people to lead all federal agencies, only one nomination,
for Director of National Intelligence, has been voted on by the Senate as
of press time. This leaves all
other federal agencies under “acting” control.
While many contractors will hopefully not need to go to an acting agency
head to resolve problems, some may.
Further, the names of acting people often point to either the most
senior career people, or those who may become permanent appointees. Either way, these are definitely people
worth knowing. Senior career
people, for example, can be great contacts for future ideas and
opportunities. Katy Kale
is the acting administrator at the General Services Administration. Kale has been appointed deputy administrator
and will lead the agency until an appointee is confirmed. She led the Biden GSA transition team and
previously served as GSA Chief of Staff during the Obama Administration. Sonny Hashmi is the new FAS
Commissioner at GSA. He formerly
served as GSA CIO. David Norquist,
Deputy Secretary of Defense, is now acting DOD head. He has held various positions in DOD for
about 20 years. Acting DHS Secretary
David Pekoske, normally in charge at TSA, may find himself in that position for
the maximum allowable time as at least one Senator has already put a
“hold” on the nomination of Alejandro Mayorkas to be permanent
DHS Secretary. Indeed, expect
holds and delays on other nominees as well.
As noted above, former GSA CIO Sonny Hashmi has
been named Commissioner of GSA’s Federal Acquisition Service. Hashmi’s LinkedIn profile lists an extensive
background in all things IT-related.
Balancing and prioritizing FAS’ $30 billion IT portfolio – from the
acquisition perspective – will definitely be one challenge, but Hashmi will
face other pressing issues, as well. One
will be how to work with FAS service portfolio leaders on transitioning
the very popular OASIS contract vehicle to the next generation. One key here is to ensure that major OASIS
customer agencies are on-board with whatever approach the agency takes. Another area to watch will be Hashmi’s
views on the Multiple Award Schedule program. While previous FAS and GSA leadership was
supportive of that program, that has certainly not always been the case. Will Hashmi view the Schedules as an important
FAS asset, or as an uninteresting polyglot of contracts, only from which about
half of the revenue is IT-related?
How to manage the commercial E-Marketplace pilot will likely
garner some early attention. This pilot,
mandated by Congress, is starting slowly and is likely facing competition for
resources and support inside FAS from other acquisition channels. Within IT, there is the need to ensure
that the ASTRO and POLARIS contracts are properly launched, that other
socio-economic contracts are awarded on a timely basis, and a push for customer
agencies that are slow to update their telecom networks via the EIS
contract. Internally, he will have to
continue to oversee the implementation of FAS IT assets used to support all of
these programs. Each organization
inside FAS is led by strong personalities, each with their own constituencies. Hashmi will have to balance an ability to
synthesize input from all of these sources while still keeping a firm hand on
the FAS helm. We look forward to working
with him again in his new role.
Any government contractor that’s been in a meeting with government
acquisition officials over the past several years has heard the term “PALT”. Heads nodded, as if the term was already
well-defined and understood to be part of the acquisition planning
process. This was not the case, though,
until recently. “PALT” –
short for Procurement Administrative Lead Time” (not Procurement As Live
Theater) – now has a concise definition and guiding benchmarks thanks to
a memorandum from the Office of Federal Procurement Policy (OFPP) in
the closing days of the Trump Administration.
The new standard PALT definition is “the time between the date on which
an initial solicitation for a contract or order is issued by a federal
department or agency and the date of the award of the contract or order.” This language is consistent with the
underlying NDAA legislation directing OFPP to provide additional guidance. PALT data for specific procurements
will also be included on GSA’s Federal Procurement Data System – NG. As such, it will be publicly available to
contractors and others who can, in turn, use the information to guide their own
business plans concerning a specific acquisition. Longer-term, the intent of the PALT guidance
is to find measurable, repeatable ways to reduce acquisition lead times. OFPP believes that Best in Class (BIC)
contracting has already saved millions and are optimistic that PALT data can
lead to similar time savings
Many of us may have heard this amusing line before, but it is, unfortunately,
the way many government contractors approach compliance. There’s nothing funny about that. That unidentified small object in the
distance can really pack a punch if you don’t deal with before it can knock you
for a loop. All too often, companies
get knocked for a loop. Then
some version of the seven stages of grief kicks in, with denial usually being
the largest. The problem is larger, and
exponentially more expensive to deal than if it had been addressed when first
observed in the outfield. It’s not just
company expense. People can, and
frequently do, lose their jobs as part of a company clean up. Don’t let any of this happen to you. Allen Federal can provide an overview
of your contract compliance systems, make recommendations on changes, and even
work with counsel if necessary.
Compliance is pennies on the dollar.
Contact us today at info@allenfederal.com to see what we can
do for you.