Program Manager/Contracting Officer

February 23, 2015

Ryan Schrank

General Services Administration

20 North 8th Street #8

Philadelphia, PA 19107

Re: FSSI Print Management 2.0

Dear Ryan,

The Coalition for Government Procurement sincerely appreciates the FSSI Print Management program’s outreach to industry regarding the next generation strategic sourcing contract for managed print services (MPS). The purpose of this letter is to provide GSA with input from industry on the future of the current FSSI print management contract.

The Coalition for Government Procurement (“the Coalition”) is a non-profit association of firms selling commercial services and products to the Federal Government. Our members collectively account for approximately 70% of the sales generated through the GSA Multiple Award Schedules (MAS) program and about half of the commercial item solutions purchased annually by the Federal Government. Coalition members include small, medium and large business concerns. The Coalition is proud to have worked with Government officials over the past 35 years towards the mutual goal of common sense acquisition.

As you know, members of the Coalition’s Imaging Equipment Committee believe that when properly applied, managed print services allow customers to right-size their fleets and achieve significant savings. We are concerned however that a number of factors have made it more difficult for the Federal government to adopt managed print services compared with the commercial market. Examples are 1) many agencies do not allow asset management software on their networks, and 2) agencies separate the Needs Assessment from the follow-on equipment purchases in separate solicitations.

As a result, despite the efforts of GSA’s FSSI Print Management program and others, the FSSI Print Management contract has not achieved its potential or its originally stated objectives. Based on Coalition members’ experience as contractors under the current FSSI contract, we recommend that the FSSI Print Management contract end at its expiration date in September 2016 rather than continuing to a second generation. The acquisition of managed print services beyond this date should be executed through GSA’s Schedule 36. We believe that the FSSI Print Management contract should be allowed to expire due to:

1. Low adoption of managed print services by Federal agencies.

2. Low contract sales.

3. The ability of an already existing contract vehicle, Schedule 36, to handle FSSI contract orders more efficiently and effectively with the potential for greater cost savings for agencies.

Low Adoption of Managed Print Services

The vast majority of sales conducted under the current FSSI Print Management contract have been for equipment purchases under Functional Area II (Device Plus). If an agency does not base these purchases on the results of a needs assessment from Functional Area I, it is strictly an equipment purchase and not really a “managed print services” buy as envisioned by the FSSI Print Management contract. MPS occurs when the agency customer utilizes the capabilities offered through all the Functional Areas originally under the FSSI contract, from Needs Assessment, to Device Plus, to Management of Existing Imaging Devices. The Coalition is currently unaware of any Federal customer that has utilized the FSSI contract this way.

Low Contract Sales

Sales under the FSSI Print Management contract are much lower than expected. Based on commitment letters included in the RFP for ______, the estimated value of the contract in __year__ was $_____. In FY 2014, contracting volume under the FSSI contract was $13.2 million—only 5% of sales under Schedule 36 SINs that offer the same products and services. Further, FY 2014 sales were only 1-2% of the contract volume within this scope in the open market. Given the costs associated with basic contract management and data reporting under the FSSI contract vehicle, it is difficult for contractors to continue to justify participation in this FSSI contract beyond 2016—especially when a more cost-effective and efficient government-wide contract already exists, Schedule 36.

Schedule 36

GSA’s Schedule 36 is an already existing government-wide contract vehicle that offers the imaging equipment and associated services available under the FSSI contract through SINs 51 100, 51 100C, 51 100F, 51 58, and 51 501. In response to specific requirements at the task order level, Schedule contractors offer competitive pricing on these items for customer agencies. Contractors report that pricing available for products and services under the Schedules program are often lower than pricing available under the FSSI Print Management contract. This is due to higher contract management costs associated with data reporting and other requirements under the FSSI contract. In short, contractors find it more cost effective and efficient to offer imaging equipment to agencies through Schedule 36. The sales data for the FSSI Print Management contract indicates the same for customer agencies. Following the launch of the FSSI contract, it was anticipated that much of the sales volume under Schedule 36 would move to the new FSSI contract vehicle. However since the FSSI Print Management contract was launched in 20__, this trend has not materialized. In FY 2014, the vast majority of copier, multi-functional device and printer sales under Federal contracts went through the Schedules program. Again, the contract volume under the FSSI Print Management contract in 2014 only represented 5% of the sales for similar items under Schedule 36. Clearly agencies purchasing imaging equipment have shown a preference for the Schedules program compared to the FSSI contract.

Recommendations

Although few Federal agencies have embraced print management services to date, the Coalition continues to believe that MPS (and especially right-sizing fleets) have potential for agencies to achieve significant savings. We hope that in the coming years, some of the barriers to the adoption of MPS will be addressed—such as agency concerns about allowing asset management software on the network. Coalition members appreciate the efforts that GSA has already made in this regard, and are committed to working with the government to further address these barriers.

Again, the Coalition does not believe that a second generation FSSI Print Management contract is in the interest of customer agencies, contractors or taxpayers. The FSSI government-wide contract should be allowed to expire in September 2016. Instead, we suggest an approach that is more consistent with the Category Management initiative described in the December 2014 OFPP “Transforming the Marketplace” memorandum. The following recommendations encourage GSA to share best practices information on managed print services, identify a program expert to assist customer agencies with MPS purchases and maximizes the use of an already existing contract vehicle, Schedule 36. Best practices information and expertise could be shared with customer agencies through a Common Acquisition Platform “hallway”. The Coalition suggests that GSA:

1. Maintain a program expert on imaging to assist SIN 51 500 Managed Print Services and SIN 51 501 Needs Assessment and Analysis Services customers in several ways including:

a. Developing guidelines that agencies can use as a road map to acquiring copiers, printers and multifunctional devices.

b. Working with agencies to ensure they complete needs assessments, prepare appropriate SOWs, and take other actions to reduce costs by right sizing their inventory of copiers, printers and multifunction devices.

c. Working with customer agencies to improve the end of fiscal year process of renewing orders.

d. Working with GSA contracting to identify alternatives to non-commercial contract terms.

2. Establish sample ordering procedures and a model Managed Print Services BPA that agencies can use at the agency or sub-agency level.

3. Educate current customer agencies under the FSSI Print Management contract about the Schedules program and the SINs available under Schedule 36 that can meet their requirements.

4. Review SIN 51-501 for Needs Analysis and Assessment and ensure that contractors are allowed to provide evaluation and assessment services the same as they do commercially. Currently contractors do not operate in the same manner with respect to Government customers because of fear that if they make an assessment and recommendation they will be “conflicted out” of the resulting equipment purchase. The Coalition believes that there would be no actual conflict of interest if using the MAS ordering procedures; an agency invites three or more contractors to submit pricing proposals based on the contractor’s assessment and evaluation. All contractors would have access to the same information.

5. Work with government and industry to address security concerns related to the use of asset management software on government networks. Determine whether FedRAMP certification is the best path forward to increase the adoption of this software solution by Federal agencies and support the certification of these tools as appropriate.

The Coalition looks forward to continuing the dialogue with you on the future of the Managed Print Services program at GSA. Thank you for the opportunity to submit our recommendations. If there are any questions, I may be reached at (202) 331-0975 or .

Sincerely,

Roger Waldron

President