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I hope the GSA will either abandon this approach and start over or seriously rework the rule prior to it ends up being final. This is a concern the Subcommittee will be keeping track of and will continue to monitor, and we anticipate having another opportunity to meet you if that is very important.

Without objection, so ordered. And thank you again. Intro Mr. Chairman and Members of the Committee, my name is Sheila Armstrong.

The Proposed Guideline does not apply to VA --------------------------------------------------------------------------- FSS agreements in the pilot program. GSA grossly ignores both implementation expenses and compliance expenses of transactional data reporting.

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Third, it does not appear that GSA is specific how it will use the abundant quantity of information that it looks for to gather under the Proposed Guideline, however the capacity for down pricing pressure that likely will arise from transactional data reporting might have an out of proportion result on small companies who seldom win a "race to the bottom" on prices.

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This data likewise is protected from disclosure under the Trade Secrets Act. Select Congress Concerning the Proposed Transactional Data Guideline A. Approximated Application and Reporting Expenses of the Transactional Data Guideline GSA approximates that the public reporting problem for its professionals to at first set up systems for transactional information reporting at six hours. 3 GSA approximates that the regular monthly problem thereafter will average 4 approximately 0.

e - GSA SER. sales) and assumes regular monthly reporting burden rises with supplier sales based on the distribution of sales and commitments within FSS agreements and non-FSS agreements." 6 What GSA permits no time for is system improvements that may be needed should GSA choose to change the fields of information to be reported as it would have the right to do upon 60 days notification under the Proposed Guideline. 7 In addition, these estimates of 6 hours for preliminary set-up and 31 minutes each month for ongoing reporting are grossly undervalued.

9 This estimate likewise consists of the effort that GSA expects professionals will be needed to make to institute modifications to specialist training, compliance systems, settlements, and audit preparation-- and presumably includes the time and expense required to customize information- event, reporting, and information-technology (IT) systems to accurately and efficiently report the information required by the Proposed Guideline. 10 GSA's own Inspector General's office acknowledges that professionals likely will invest far more than 6 hours to set up business systems for transactional information reporting. 11 As the GSA Office of Inspector General keeps in mind in its comments to the Proposed Rule: --------------------------------------------------------------------------- 8 Id.

Given this, we question whether GSA's estimate of 6 hours per specialist to configure their --------------------------------------------------------------------------- systems for reporting is accurate - GSA Search Engine Ranker. 12 12 Id. This six hour estimate must assume that all information fields reside in the very same IT system and that the report can be established by a single person without consultation with others inside or outside the company.

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In numerous cases, the systems that house the various fields GSA is requesting in its monthly report are not set as much as interact with one another. Appropriately, some professionals will need to manually assemble the info needed for transactional information reporting, or might need to update their IT systems in --------------------------------------------------------------------------- order to comply (GSA SER Services).

For some contractors, particularly small companies, setting up systems to catch and report transactional data may include assessment with professionals outside the company at hourly rates therefore increasing the costs to the professional. These estimated costs are not factored into GSA's six hour price quote for set up. 13 --------------------------------------------------------------------------- 13 As kept in mind in the ABA's Remarks to the Transactional Data Rule: The Section suggests that the hours required will in truth be much greater.

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Numerous professionals might need considerable modifications or upgrades to company systems in order to offer the data sought by GSA in a kind that will enable significant and accurate rates contrast as intended. The fields required by GSA for transactional-data reporting might not live in the same IT system; few accounting systems consist of both producer part number and professional part number in the exact same system when those part numbers differ.

g., products management) to meet the requirements of the Proposed Rule. These and other needed changes would need coordination amongst functions such as the specialists' IT departments and change management teams as well as accountable executives. The time needed just to look for, extract, evaluation, and test such information, and execute system adjustments, will well go beyond 6 hours.

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The approximated 31 minutes per month does not consist of any time permitted for ongoing upkeep of information, including but not limited to changes by GSA to the data fields needed as allowed by the Proposed Guideline. 14 Given the unknown ramifications on a contractor ought to it provide data to GSA that is incorrect or incomplete, professionals will require to review the transactional data prior to submission which could take hours depending upon the size of the contract.

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--------------------------------------------------------------------------- 14 80 Fed. Reg. 11628. B. GSA's Proposed Expansion of Commercial Sales --------------------------------------------------------------------------- Practice Disclosure Requirements is Unduly Troublesome All GSA contractors need to prepare and submit CSPs prior to award and at particular crucial times throughout efficiency of a GSA contract. For instance, when a professional looks for to increase costs or include products to the agreement GSA requires either new CSPs, or a statement from the contractor that the CSPs have not changed considering that the time they were last submitted.

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Due to the prospective monetary risks produced by unreliable CSP disclosures, contractors must invest substantial time reviewing sales data and preparing present, accurate and complete CSPs when they are required to do so (GSA Search Engine Ranker). Even a declaration that the CSPs have actually not changed requires comprehensive evaluation of transactional sales information to confirm that this declaration is right at the time that it is made.

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