On May 2, 2019, the General Services Administration (“GSA”) and the Office of Management and Budget (“OMB”) finally released their Phase 2 Implementation Report (the “Phase 2 Report”) for “Procurement Through E-Commerce Portals,” as directed by Section 846 of the National Defense Authorization Act for Fiscal Year 2018 (“FY 2018 NDAA”).
GSA/OMB offered a sneak preview of the Phase 2 Report at an Industry Day held on December 12, 2018, during which GSA/OMB revealed their intent to proceed with a proof of concept contract utilizing only the E-Marketplace model. Industry pushback against a single model proof of concept was both quick and severe and, coupled with the lengthy delay issuing the Phase 2 Report, many wondered whether GSA/OMB were reevaluating their proposed approach.
Much to the dismay of E-Commerce and E-Procurement portal providers, GSA/OMB stayed the course. Their Phase 2 Report included two primary conclusions: (1) testing the E-Marketplace model exclusively during the proof of concept phase is the most practical approach, and (2) raising the Micro-Purchase Threshold (“MPT”) to $25,000 for 5 years exclusively for purchases made through the approved portals is necessary to maximize the effectiveness of the proof of concept.
While the Phase 2 Report provides these two concrete conclusions, ultimately, the Report raises more questions than answers. And what better way to address these than a good old-fashioned Top 10 List. So, without further ado, here’s our Top 10 List of questions from the Phase 2 Report…
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