In the Wake of the Polaris Pause: Are GWACs the Best Way to Help Government? (Opinion)
In big news in the government-contracting arena, the GSA has officially halted the award of the $15 billion Polaris governmentwide acquisition (GWAC) contract. The agency plans on assessing the merits of a pre-award challenge over how the prior experience of small businesses is treated as part of the solicitation.
According to this recent Washington Technology article, the procurement terms currently allow firms involved in mentor-protégé arrangements to rely solely on the experience of larger, mentor companies.
The goal of Polaris is to ultimately support small businesses. However, the scorecard proposals only reward businesses that have been established and are able to do the work. As a result, many small businesses are considering not bidding.
The latest Polaris news reinforces other challenges that have happened with similar GWACs. We don’t need to dive into the fiasco that was the NITAAC CIO SP4 solicitation, another best-in-class (BIC) small business vehicle.
In addition, GWACs with more explicit technical focuses, like NASA SEWP or GSA OASIS, are more viable in the long term. With tailored technical scopes, these contracts provide customers with a clear understanding how they can be used to acquire labor services.
Nebulous contract vehicles with never-ending technical functional areas often devolve into chaos—with very little funding actually making it to small businesses.
There Needs to Be IT-Specific Focus Areas for GWACs
The predecessor NITAAC vehicle, CIO-SP3, was supposed to be the best and the brightest in the health IT sector. However, with this vehicle, all of Government issues task orders that do not touch public or health management concerns.
By attempting to appeal to all federal customers, this creates an intense industry response to be on as many of these vehicles as possible. That is why the Government sees complicated and risky teaming arrangements designed to address the broad scope of requirements.
Along these lines, STARS III was designed to be the entry-level 8(a) BIC while also focusing on Emerging Technology requirements. There are almost 1,000 small businesses on this GWAC, which is overwhelming for government contracting officers.
In addition, STARS III government-contracting officers will likely deal with a mixture of quality and maturity of bidding companies. There is also aggressive price competition because many bidding companies want to get their feet in the door. In the end, when price is the priority, quality and effectiveness can often get compromised. Some of this was seen and felt on STARS II.
Polaris is designed to be for the top 100 small business federal contractors with the maturity to deliver at a high-level and proven and prior history to deliver for federal customers. Everyone who wins this vehicle deserves to be there.
Yet, it will still address the entire federal marketplace, therefore what is its differentiator from CIO SP4? It also addresses Emerging Technology, the branded focus area by GSA for STARS III.
When a Contracting Officer issues an Emerging Technology RFI on Polaris and STARS III seeking SB capabilities, we would expect that they would generally be receiving 4-5 strong responses with past performance by vendors as the federal prime from Polaris -- versus 10-15 responses from vendors with significant federal subcontracting experience. This waters down what the GSA hoped to achieve with STARS III.
With hindsight being 20/20, the STARS III GWAC should have been re-structured so that it was limited to just the 8(a) small business itself. 8(a) Joint Ventures and Mentor-Protégé arrangements should be encouraged to get GSA Multiple Award Schedules (MAS).
Essentially, STARS III should have then been used for staffing supplementation, proof of concept, or shootout type contracts. Contracting officers could issue RFIs and get responses or potential resumes from 4-5 vendors. Those could be invited for formal negotiations and technical demonstrations with the agency awarding a sole source award.
This would incentive agencies to start experimenting with small dollar ideas ($500,000 to $2,000,000 budgets) to develop pilots or prototypes or to enhance current program delivery. It could aid end of year spending by finding cleared personnel capable of supporting immediate staffing needs.
CIO SP4 should be used primarily by the Department of Health and Human-Services and other agencies when Task Area 1 (IT Services for Biomedical Research, Health Sciences, and Healthcare) is a mandatory requirement of the solicitation.
It is our belief that GWACs with more explicit technical focuses, like NASA SEWP (hardware and software) or GSA OASIS (technical engineering), are more viable in the long-term. With tailored technical scopes, these contracts provide customers with a clear understanding how they can be used to acquire professional consulting services.
In the end, it’s very likely that the same 100 vendors will be on Polaris, as well as on CIOSP3 and a majority of them also on STARS III – with no differentiation between the focus areas of the vehicles. As a result, the Government does not gain access to a wide-range of solutions and services from the actual federal IT marketplace.
In addition to an IT focus prioritization, how else can government best manage this contracting category confusion, and best use these GWACs to advance IT modernization?
Create a Mid-Size Category and More Clarity
We recommend creating a mid-sized category where graduated small businesses don’t have to compete with the billion dollar systems integrators—let them compete against each other.
In addition, consider developing entry-level vehicles that don’t require mentor-protégé or JV arrangements, and help springboard smaller companies into the arena on smaller programs and efforts. We need the opportunity to build federal prime contractor experience, it doesn’t have to be on $20M task orders.
Each agency should also consider developing their own BPAs. This would allow them to get specialized solutions and teams that truly fit their mission needs – while giving smaller businesses more opportunity to participate.
Also, while agency-level BPAs are considered a step below Best in Class Tier 2, they still fit into the overall category management. More agency-level BPAs on GSA MAS vehicles creates more focused solutions for the agencies themselves. If customers are hesitant for the administrative burden of managing these BPAs, GSA should focus on addressing this for them to encourage this for their technology benefit.
Government should also consider moving away from scorecards that are based on things that small companies cannot control, such as DCAA audits and facility clearances. These scorecards are actually designed to favor companies that are already established, and are often in the DoD space. DoD and Civilian agencies are not the same.
The reality is that many smaller businesses are developing the most cutting-edge innovations, and can truly help government to achieve full-scale IT modernization. They are the ones ready to actually address your need rather than present it to you on a PowerPoint deck. Tapping into the small business community can provide a tremendous benefit for both government and industry.
Conclusion
Managing these large-scale GWACs surely takes a herculean effort by the GSA to ultimately bring them to life, and we applaud these efforts.
As members of the small business community, we share the same passion and dedication as our government counterparts, and we all want the same thing: to support the mission of government.
By re-thinking how new and innovative players can enter the market, while also structuring BPAs for individual agencies, it is possible to procure the right solutions for the right agency for long-term mission success.