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GSA Faces Push-Back on Proposed Rule Eliminating PRC

By Lorraine M. Campos & Paula Salamoun on April 21, 2015
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Reed Smith attended last Friday’s General Services Administration’s (GSA) public meeting on the proposed Transactional Data Reporting rule. GSA’s proposed rule would eliminate the Price Reduction Clause (PRC) in favor of transactional data reporting. We previously blogged about the parameters of the proposed rule here. GSA held this meeting in the hopes of opening dialogue on this significant change in policy.

Throughout the meeting, GSA faced skepticism from interested members of the public, as well as from the GSA’s Office of the Inspector General (“GSA OIG”) and Veteran Affair’s Office of the Inspector General (“VA OIG”). Interested members of the public voiced privacy concerns regarding the potentially sensitive commercial data GSA would collect through the proposed rule, and the interplay with the Freedom of Information Act. Questions linger as to the details of data collection and who will have access to such data, with GSA noting that this will require further consideration. Interested members of the public also noted the practical and logistical difficulties in meeting the reporting burdens, leaving some commentators to believe that GSA had significantly underestimated such burdens. GSA also faced criticism from intergovernmental entities. GSA OIG and VA OIG both cited concerns that the new proposed rule would strip the government from pricing protections afforded to it by the PRC.

Anne Rung, administrator of the Office of Federal Procurement Policy, was notably in attendance and gave comments reflecting her vision for federal procurement: simplicity and collaboration supported by a newly trained team of acquisition specialists using industry best practices. Rung does not believe that GSA’s proposed rule deviates from the focus on best value. Kevin Youel Page, Federal Acquisition Service Deputy Commissioner, echoed Rung, noting that this rule is not just meant to seek the lowest price possible, a concern that some have voiced.

Given the saliency of the PRC to government contractors, Reed Smith will provide in-depth analysis of the meeting over the coming days.

Photo of Lorraine M. Campos Lorraine M. Campos

Lorraine M. Campos is a partner and member of the Steering Committee of Crowell & Moring’s Government Contracts Group and focuses her practice on assisting clients with a variety of issues related to government contracts, government ethics, campaign finance, and lobbying laws. Lorraine…

Lorraine M. Campos is a partner and member of the Steering Committee of Crowell & Moring’s Government Contracts Group and focuses her practice on assisting clients with a variety of issues related to government contracts, government ethics, campaign finance, and lobbying laws. Lorraine regularly counsels clients on all aspects of the General Services Administration (GSA) and the U.S. Department of Veterans Affairs (VA) Federal Supply Schedule (FSS) programs. She also routinely advises clients on the terms and conditions of these agreements, including the Price Reduction Clause, small business subcontracting requirements, and country of origin restrictions mandated under U.S. trade agreements, such as the Trade Agreements Act and the Buy American Act. Additionally, Lorraine advises life sciences companies, in particular, pharmaceutical and medical device companies, on federal procurement and federal pricing statutes, including the Veterans Health Care Act of 1992.

Lorraine has been ranked by Chambers USA since 2013, and she was recognized by Profiles in Diversity Journal as one of their “Women Worth Watching” for 2015. Additionally, Lorraine is active in the American Bar Association’s Section of Public Contract Law and serves as co-chair of the Health Care Contracting Committee.

Lorraine joined the firm from Reed Smith, where she chaired their Government Contracts & Grants Team since 2010. Prior to that, she worked as a consultant for Grant Thornton, where she advised the Intelligence Community, analyzed the Department of Defense utility privatization program, and performed numerous Circular A-76 studies for the Office of Management and Budget.

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Photo of Paula Salamoun Paula Salamoun
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  • Posted in:
    Government Contracts
  • Blog:
    Global Regulatory Enforcement Law Blog
  • Organization:
    Reed Smith LLP

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