Contract Management: Not Following Procedures Undermines Best Pricing
Under GSA's Schedule (Letter Report, 11/28/2000, GAO/GAO-01-125).

The Department of Defense (DOD) spends millions of dollars each year to
acquire information technology (IT) services through the General
Services Administration's (GSA) Federal Supply Schedule (FSS). However,
DOD has not been taking steps critical to ensuring that it is getting
the best services at the best prices. GAO's review of 22 DOD orders
revealed that 17 of them were placed without seeking competitive quotes.
GSA's established procedures require that agencies seek competitive
quotes to ensure that the government gets the best price for IT
services. Many DOD contracting officers were not aware of this
requirement and thus placed orders under FSS contracts without seeking
quotes from multiple contractors. The Federal Acquisition Regulation
covering FSS contracts does not provide clear guidance to contracting
officers concerning these special ordering procedures.

--------------------------- Indexing Terms -----------------------------

 REPORTNUM:  GAO-01-125
     TITLE:  Contract Management: Not Following Procedures Undermines
	     Best Pricing Under GSA's Schedule
      DATE:  11/28/2000
   SUBJECT:  Procurement regulations
	     Federal supply systems
	     Information technology
	     Internal controls
	     Defense procurement
	     Defense cost control
	     Federal procurement policy
IDENTIFIER:  Federal Supply Schedule

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GAO-01-125

A

Chairman and Ranking Minority Member, Subcommittee on Readiness and
Management Support, Committee on Armed Services, U. S. Senate

November 2000 CONTRACT MANAGEMENT

Not Following Procedures Undermines Best Pricing Under GSA's Schedule

GAO- 01- 125

Letter 3 Appendixes Appendix I: Scope and Methodology 14

Appendix II: Information on Selected Orders 15 Appendix III: Comments From
the General Services

Administration 17 Appendix IV: Comments From the Office of Federal
Procurement Policy 21

Appendix V: GAO Contacts and Staff Acknowledgments 23

Lett er

November 28, 2000 The Honorable James M. Inhofe Chairman The Honorable
Charles S. Robb Ranking Minority Member Subcommittee on Readiness and
Management Support Committee on Armed Services United States Senate

Federal spending for goods and services has changed significantly in recent
years. The government now spends more on services- ranging from basic
maintenance to running computer systems- than on supplies and

equipment. The government acquisition process has also changed in terms of
how the government buys. In particular, the process has become more
streamlined as new contract vehicles and techniques have allowed agencies to
buy what they need much faster than in the past. 1 To streamline its own
acquisitions, the Department of Defense (DOD) is making extensive use of
contracts awarded by other agencies, including contracts

that the General Services Administration (GSA) awards to multiple companies
supplying comparable products and services under the Federal Supply
Schedule. 2

In view of concerns that there is inadequate oversight and accountability
over using new contract vehicles and techniques to acquire services faster,
you requested that we assess whether DOD is using the Federal Supply
Schedule to purchase information technology services in a manner that
maximizes competition. As agreed with your offices, our specific objectives
were to assess whether contracting officers were following established

procedures to ensure fair and reasonable prices and whether guidance and
regulations regarding purchases under the Federal Supply Schedule were 1 A
General Services Administration- contracted study found that it takes only
15 days to

place an order under a Federal Supply Schedule contract versus 268 days to
award a contract using the traditional method. 2 The Federal Supply Schedule
is also called the Multiple Award Schedule (MAS). Under the program, GSA
negotiates contracts with vendors for a wide variety of mostly
commercialtype products and services at varying prices. These contracts
permit other agencies to place orders directly with the vendors.

adequate. We did not assess whether DOD in fact obtained fair and reasonable
prices on specific orders.

In conducting our review, we identified four large buying commands,
including one for each military department. From these four commands, we
selected the largest orders for information technology services purchased in
fiscal year 1999 using the Federal Supply Schedule. In total,

22 orders were selected, which represented about $112. 7 million. Appendix I
contains details on our scope and methodology.

Results in Brief Most DOD contracting officers included in our review did
not follow GSA's established procedures intended to ensure fair and
reasonable prices when using the Federal Supply Schedule. In fact, 17 of the
22 orders- valued at $60.5 million- were placed without seeking competitive
quotes from

multiple contractors. Instead, in placing the 17 orders, contracting
officers often relied just on a comparison of labor rates of various
contractors listed on the Federal Supply Schedule and generally ended up
placing the orders with incumbent contractors. Relying on labor rates alone
does not offer an agency a good basis for deciding which contractor is the
most competitive

since it does not reflect the full cost of the order or even critical
aspects of the service being provided, such as the number of hours and mix
of labor skill categories needed to complete the work. The key reason that
established procedures were not followed is that many contracting officers
were not even aware of GSA's requirement to seek competitive quotes. Also,
guidance for the program is not clear. In particular, the Federal
Acquisition Regulation does not make distinctions between services and
products, and the regulations do not inform contracting officers that GSA's
special ordering procedures for services even exist. Most contracting
officers were not aware of the ordering

procedures for services at the time the orders included in our survey were
placed. In addition, the ordering procedures do not address whether
solesource orders are permitted and what procedures to use for such orders.

By not following the Federal Supply Schedule requirement for competitive
quotes, DOD has significantly undermined its ability to ensure that it is
getting the best information technology services at the best prices.

Moreover, the lack of clear guidance on when to seek competitive quotes for
services has increased the risk that agencies will not identify and acquire
the lowest cost alternatives to meet their needs. This report makes
recommendations for GSA and the Office of Federal Procurement Policy

aimed at promoting more competition for orders and providing additional
guidance to agencies using the Federal Supply Schedule. GSA and the Office
of Federal Procurement Policy agreed with our recommendations and their
written comments are contained in appendixes III and IV. Background Over the
past several years, the government has purchased billions of

dollars each year in information technology products and services using the
Federal Supply Schedule. The Schedule provides federal agencies with a
simplified and streamlined process to obtain commonly used products and
services at prices associated with volume buying. Sales under the

Federal Supply Schedule for information technology services increased from
$1.2 billion in fiscal year 1998 to about $4.4 billion in fiscal year 2000.

Under the Federal Supply Schedule, GSA awards contracts to multiple
companies supplying comparable products and services. These contracts can be
used by any federal agency to purchase commercial products and services. As
a general rule, the Competition in Contracting Act of 1984 requires that
orders under the Federal Supply Schedule result in the lowest overall cost
alternative to meet the needs of the United States. 3 The Federal
Acquisition Regulation instructs government ordering offices to review

catalogs or price lists of at least three contractors and place orders for
the alternative that represents the best value and results in the lowest
overall cost alternative (considering price, special features, etc.) to meet
the

agency's needs. Traditionally, the Federal Supply Schedule covered only
products, such as office equipment. In 1998, GSA issued special ordering
procedures for services. At the time of our review, these procedures
required ordering

agencies to seek competitive quotes for services priced at hourly rates. 4
Specifically, they were required to (1) prepare a request for quotes, (2)
send the request for quotes to at least three Federal Supply Schedule
contractors based on an initial evaluation of catalogs and price lists, and
(3) evaluate the quotes and select the contractor to receive the order based
on factors

3 If this requirement is met, and the program has been open to all
responsible sources, the competition requirements of the Competition in
Contracting Act are satisfied. See 10 U. S. C. sect. 2302( 2)( C) and 41 U. S.
C. sect. 259( b)( 3). 4 In July 2000, GSA revised the ordering procedures for
services. These procedures now apply to an order for services that requires
a statement of work.

identified in the request. The ordering procedures also state that the
office ordering the services (ordering office or program office) is
responsible for considering the level of effort and mix of labor proposed to
perform specific tasks and for making a determination that the total price
is fair and reasonable.

Few Competing Quotes On 17 of the 22 orders we reviewed- totaling $60.5
million- contracting for Information

officers did not solicit quotes because they were unaware of GSA's
requirement to seek competitive quotes at the time the orders were placed.
Technology Orders

Rather than obtaining competitive quotes, in most cases, DOD contracting
officers reviewed the hourly labor rates for various contractors listed on
the Federal Supply Schedule and placed the orders. In four of these cases,

DOD contracting officers believed there was only a single source that could
meet the government's needs. In most of the cases, contracting officers used
the Federal Supply Schedule as a convenient and quick way to place

orders with incumbent contractors. Appendix II provides more detailed
information on each of the 22 orders.

The Federal Acquisition Regulation provisions covering the Federal Supply
Schedule do not provide clear guidance to contracting officers concerning
the procedures to use to order services. The regulations do not make
distinctions between services and products, and do not inform contracting
officers that special ordering procedures for some types of services even
exist. Equally important, GSA's current ordering procedures, which GSA

now says apply to services that require a statement of work, do not specify
the types of services for which a statement of work is required. During our
review, GSA began the process to incorporate the ordering procedures for
services into the Federal Acquisition Regulation.

Table 1 shows the extent that the government contracting officers at four
locations (see app. I) that we visited sought competitive quotes on the 22
orders that we reviewed.

Table 1: Summary of Selected Orders Orders placed without seeking
competitive quotes Number of

orders Location

reviewed Number Value

Electronic Systems Center 5 0 0. 0 Communications- Electronics

5 5 $12.1 Command Space and Naval Warfare Systems 5 5 29. 7

Center Defense Supply Service 7 7 18. 7

Total 22 17 $60. 5

The table shows that only one of the four locations that we visited- the
Electronics Systems Center at Hanscom Air Force Base- sought competitive
quotes before placing an order for information technology services. The
Center had developed a centralized program to manage its

service contracts. Moreover, government contracting officers at the Center
sought and received competitive quotes on the five orders selected for
review. In placing the orders, the Center established criteria to evaluate
the quotes and documented its decisions.

At the other three locations, DOD contracting officers did not seek
competitive quotes before placing an order for information technology
services. The following examples illustrate the steps that DOD contracting
officers performed instead.

Orders were placed with two incumbent contractors to continue providing
information technology support services to the Office of the Secretary of
the Air Force. For these orders, the DOD ordering office advised the
contracting officer that the incumbent contractors were most familiar with
the current systems and that loss of either would

have a detrimental effect on their mission. In addition to estimates for the
work by the incumbent contractors, the ordering office also provided the
contracting officer with labor hour rates from the Federal Supply Schedule
for two other contractors- both higher than the incumbent contractors. The
contracting officer received quotes from only the two incumbent contractors.
The government contracting officer issued orders for about $3. 1 million and
about $1. 5 million to

these incumbent contractors. One of the contractors proposed labor rates
that were substantially below its Federal Supply Schedule rates but
consistent with rates charged for the prior year. The other contractor's
rates were consistent with its schedule rates. In neither case did the
contracting officer request price reductions. The

contracting officer told us that they were unaware of the GSA ordering
procedures that required competitive quotes. The contracting officer pointed
out that they would have followed the ordering procedures for services had
they been included in the Federal Acquisition Regulation. An order was
placed with an incumbent contractor to continue software development work
for the Defense Manpower Data Center. The

contracting officer did not seek quotes from any contractors, including the
incumbent contractor. Instead, the contracting officer relied on cost
estimates developed by the Data Center for the incumbent contractor to
continue providing information technology services for fiscal year 1999. The
estimates also included labor rates from the Federal Supply Schedule for
four additional contractors. Based on the labor rates, the total estimated
costs for the four contractors were all higher than the incumbent
contractor. Several weeks after receipt of the estimates, the contracting
officer issued the $2.7- million order to the incumbent. The order was based
on the labor rates contained on the Federal Supply Schedule. The contracting
officer did not request any price reductions. An order was placed with an
incumbent contractor to provide

information technology services in the design, development, integration,
deployment, and maintenance of a military human resources system for DOD's
Systems Executive Office for Manpower and Personnel. Again, unaware of the
GSA ordering procedures, the contracting officer did not seek competitive
quotes. The ordering office requested that the contracting officer place an
order with the incumbent contractor under the Federal Supply Schedule. On
this order, the contracting officer merely compared hourly labor rates for
the incumbent contractor with

hourly labor rates from the GSA schedule for two other contractors. The
contracting officer obtained a quote from the incumbent contractor and
placed an $18.5 million order for 5 months of work. The contractor's quote
was based on the contractor's labor rates (and its subcontractors' rates)
contained on the Federal Supply Schedule but included a 2- percent price
reduction. The contracting officer said that the

contractor did not give any additional price reductions during negotiations.

In these examples and in other orders we reviewed, the contracting officers
did not solicit quotes, as called for by GSA's ordering procedures, and

generally did not seek price reductions from contractors. Moreover, on 17 of
the orders we reviewed, contracting officers often relied solely on labor
rates to make a decision on acquiring information technology services. Such
rates do not provide a meaningful basis for assessing which contractor is
providing the best and most cost- effective services since they

do not reflect the total cost of the order or important aspects such as the
number of hours and mix of labor skill categories needed to complete the
work. As a result, the DOD agencies included in our review did not have all
of the information they should have had to determine that the total price of
an order was fair and reasonable and that the order resulted in the lowest
overall cost alternative meeting the needs of the agency, as required by the
Competition in Contracting Act.

Sole- Source Orders Four orders that we reviewed were placed on a sole-
source basis. In each case, DOD ordering offices advised contracting
officers that the incumbent contractors were the only contractors able to
meet government needs. At the time these orders were placed, the ordering
procedures for services did

not contain any guidance on how sole- source orders should be handled.
Although in the spring of 2000, GSA officials added to their buying guide a
statement that sole- source orders are not authorized, this statement was
not incorporated into the ordering procedures or the Federal Acquisition
Regulation. On all four sole- source orders that we reviewed, contracting
officers obtained statements from DOD program agencies concerning the need
for services from the specific contractors, received a contractor's quote
and made brief comparisons to the government estimate for labor

and GSA- approved labor rates, and then processed the orders. The following
two examples illustrate how orders were placed with incumbent contractors
for continued support of computer information systems.

The ordering office (the Army's Office of the Surgeon General) sent a brief
memorandum to the contracting officer recommending the incumbent contractor
for an order. The memorandum stated that the

contractor had performed satisfactorily and was uniquely qualified and
experienced to provide continued support. The contracting officer considered
this letter a noncompetitive sole- source justification. In placing this
sole- source order, the contracting officer requested a quote from the
incumbent contractor, had that quote evaluated by the ordering office,
reviewed the incumbent's GSA- approved labor rates, and then processed the
$1. 7- million order. The contractor's quote was based on

the labor rates listed on the Federal Supply Schedule, and the contracting
officer did not request price reductions. The Office of the Secretary of
Defense, Program Analysis and

Evaluation, sent a memorandum to the contracting officer recommending the
incumbent contractor for an order. The memorandum stated that changing its
information technology support contractor would jeopardize several ongoing
projects. Ordering office

officials told us they did not view the memorandum as a noncompetitive sole-
source justification, but rather a recommended source for their needs. In
placing this order, the contracting officer requested a quote from the
incumbent contractor, had that quote evaluated by the ordering

office, reviewed the incumbent's GSA- approved labor rates, and then
processed the $4. 3- million order. The contractor's quote was based on the
labor rates contained on the Federal Supply Schedule. However, program
officials and the contracting officer were able to negotiate labor rates
that overall were about 4.4 percent below the labor rates contained on the
Federal Supply Schedule.

Conclusions Even though it spends millions of dollars each year to acquire
information technology services through the Federal Supply Schedule, DOD has
not been taking steps critical to ensuring that it is getting the best
services at the best prices. The key reason for this is the lack of clear
guidance for the program. Specifically, the Federal Acquisition Regulation
does not indicate

that special procedures should be used to order certain types of services,
and does not describe those procedures and when they should be used. In
addition, the Regulation does not provide any guidance on the use of the
program for sole- source orders for services. The lack of clear guidance on

when to seek competitive quotes increased the risk that agencies would not
identify and acquire the lowest cost alternatives to meet their needs.

Recommendations for To encourage agencies to maximize competition in
acquiring information Executive Action

technology services, we recommend that the Administrator of the Office of
Federal Procurement Policy, as chair of the Federal Acquisition Regulatory
Council, take steps to revise the Federal Acquisition Regulation to
incorporate the requirements contained in the ordering procedures for
services to obtain competitive quotes. The Regulation should clearly

describe the procedures and when they should be used.

In addition, we recommend the Regulation address whether sole- source orders
for services may be placed using the Federal Supply Schedule. If sole-
source orders are allowed, the guidance should provide instructions

on what steps contracting officers should take to ensure that prices are
fair and reasonable and that orders result in the lowest overall cost
alternative meeting the government's needs. Pending these changes to the
Regulation, we also recommend that the Administrator of General Services
contact contracting agencies to ensure that the agencies are aware of the
ordering procedures for services and

emphasize the need for seeking competitive quotes. Agency Comments and

GSA, the Office of Federal Procurement Policy, and DOD reviewed a draft Our
Evaluation of this report. GSA's written comments are in appendix III and
the Office of Federal Procurement Policy's comments are in appendix IV. DOD
did not provide comments on this report. GSA's written comments indicated
that GSA has conducted a wide range of outreach efforts to educate agencies
on the ordering procedures. These

efforts, among other things, included making presentations at GSA seminars
and enhancing the agency's website. GSA stated that it would continue its
outreach programs and pursue additional efforts to educate agencies about
ordering procedures and the best practices for managing their buys. Despite
GSA's outreach efforts, contracting officers at three of four agencies
included in this review were unaware of the special ordering procedures for
services well after those procedures were put in place.

GSA agrees with our recommendation to revise the Federal Acquisition
Regulation coverage pertaining to the ordering procedures for services. A
draft proposed rule, currently being considered by the Federal Acquisition
Regulation Council, proposes to revise the Regulation to include the
ordering procedures for services. GSA also stated that it would ask the
Council to review our recommendation regarding the treatment of sole- source
orders for services under the program. GSA also provided a number of
technical comments, which we considered in finalizing the

report. GSA's current ordering procedures apply to services that require a
statement of work, but those procedures do not specify the types of services
for which a statement of work is required. Under the

circumstances, simply incorporating the current ordering procedures into

the Federal Acquisition Regulation would not satisfy our recommendation.
Rather, as we recommended, the amended regulation should clearly describe
procedures to be used for ordering various types of services and

when those procedures should be used. The Office of Federal Procurement
Policy's written comments also indicated that they agreed with the
recommendation to revise the Federal Acquisition Regulation pertaining to
the ordering procedures for services.

It stated that the current guidance in the Regulation provides insufficient
attention to the acquisition of services. It stated that they would be
working with the Federal Acquisition Regulatory Council to promulgate a
proposed rule that addresses the recommendations in the report as well as
some additional issues. It also stated that, in the meantime, it has been
working with GSA and DOD on a discussion paper addressing the use of
interagency contracts, such as contracts under the Federal Supply Schedule.
The discussion paper will be incorporated into a handbook that DOD is
developing to assist its buyers in acquiring commercial items.

We conducted our review from January through September 2000 in accordance
with generally accepted government auditing standards.

We are sending copies of this report to Senator John Warner, Chairman, and
Senator Carl Levin, Ranking Minority Member, Senate Committee on Armed
Services, and other interested congressional committees. We are also sending
copies of this report to the Honorable William S. Cohen, the Secretary of
Defense; the Honorable David J. Barram, Administrator of General Services;
and the Honorable Jacob J. Lew, Director, Office of

Management and Budget. We will make copies available to others upon request.

Please contact me at (202) 512- 4841 if you have any questions concerning
this report. Key contributors to this report are listed in appendix V. David
E. Cooper Director Acquisition and Sourcing Management

Appendi Appendi xes x I

Scope and Methodology We conducted our evaluation to determine whether
contracting officers maximized competition and followed established
procedures in purchasing information technology services using the Federal
Supply Schedule. We reviewed regulations and other General Services
Administration (GSA) guidance issued for the Federal Supply Schedule. We
also held discussions with GSA representatives to gain an understanding of
the Federal Supply Schedule program. In addition, we met with
representatives of the Office of Federal Procurement Policy, which is
responsible for government policy on

procurement programs. Further, we reviewed specific orders to assess whether
contracting officers sought competitive quotes. We identified the Department
of Defense (DOD) buying commands that, in total, had made large information
technology purchases of services during fiscal year 1999 under the Federal
Supply Schedule program using DOD's Individual Contracting Action Report
(DD- 350 database). Results from this database were corroborated by the
selected buying commands. The four

DOD buying commands that were selected for our review were (1) the Air
Force's Electronic Systems Center at Hanscom Air Force Base, (2) the Army's
Communications- Electronics Command, (3) the Navy's Space and Naval Warfare
Systems Center, and (4) the Defense Supply Service. In general, the largest
orders were selected for review at the four buying commands. We selected the
largest orders at each command until we had selected enough orders to exceed
$25 million in total value or we had selected all orders over $1 million.
However, we selected only one

order for each contractor to ensure an array of various contractors and
competitions. In total, 22 orders were selected for review, which
represented about $112.7 million. We did not assess whether DOD obtained

fair and reasonable prices on these orders. To determine the extent of
competition on these orders, we held discussions with contracting officers
and examined documentation in the contract files. We held discussions with
representatives of the DOD

agencies procuring the information technology services to understand their
role in the award process. We also held discussions with officials of
selected contractors to obtain information on the orders.

Appendi x II

Information on Selected Orders # Project value

Incumbent Customer/ program contractor ($ millions) Competition for order
contractor

Communication- Electronics Command

1 Information Technology Support for Army $2. 93 No competitive quotes New
requirement Program Offices Computer Science Corporation

2 Army Materiel Command Information $1. 11 No competitive quotes, review of
labor

Yes Technology rates Scientific and Commercial Systems

3 Drug Enforcement Administration $3. 68 No competitive quotes New
requirement

Worldwide Local Area Network ManTech 4 Army Systems Support for Strategic
and $2. 00 No competitive quotes Yes

Tactical Units Sytex Corporation 5 DOD Single Agency Manager

$2. 38 No competitive quotes New requirement Lockheed Martin Corporation
Defense Supply Service

6 Defense Data Manpower Center $2. 68 No competitive quotes, review of labor
Yes Systems Research and Applications

rates Corporation 7 Corporate Executive Information System $1. 74 No
competitive quotes, sole- source Yes

Performance Engineering Corporation 8 Office of the Secretary of Air Force
$3. 14 No competitive quotes, review of labor Yes Anser rates 9 Office of
the Secretary of Air Force

$1. 55 No competitive quotes, review of labor Yes Raytheon Corporation rates
10 Office of the Secretary of Defense Program

$4. 30 No competitive quotes, sole- source Yes Analysis and Evaluation
Advanced Systems Development,

Incorporated 11 Defense Medical Logistics Standard Support

$2. 76 No competitive quotes, sole- source Yes IBM Corporation 12 Single
Agency Manager - Pentagon $2. 51 No competitive quotes, sole- source Yes

Information Technology Services SETA Corporation

Space and Naval Warfare Systems Center

13 DOD Advanced Simulation Technology $2. 97 No competitive quotes, review
of labor New requirement Programs rates AB Technologies, Incorporated

14 Defense Integrated Military Human $18.50 No competitive quotes, review of
labor Yes Resource System rates Science and Engineering Associates

(Continued From Previous Page)

# Project value

Incumbent Customer/ program contractor ($ millions) Competition for order
contractor

15 National Cancer Institute Medical $3. 40 No competitive quotes, review of
labor

New requirement Data Collection System rates Oracle Corporation

16 SPAWAR Automated Tool $1. 80 No competitive quotes, review of labor

New requirement Design System rates Titan/ Eldyne Corporation

17 SPAWAR Automated Data $3. 07 No competitive quotes, review of labor Yes

Processing System rates Science Applications International Corporation

Electronic Systems Center at HANSCOM Air Force Base a

18 Global Air Traffic Operations $8. 00 Competitive quotes New a requirement
Horizon Technology Corporation 19 Strategic Nuclear Deterrence

$13.97 Competitive quotes New a requirement SenCom 20 Defense Information
Global Grid $3. 34 Competitive quotes New a requirement

ASEC (now ACS) 21 Combat Air Force Command and Control $15.10 Competitive
quotes New a requirement Dynamics Research Corporation 22 Combat Air Force
Command and Control $11.80 Competitive quotes New a requirement KKP
Corporation a All cases at the Electronic Systems Center were categorized as
new requirements because the

statements of work consolidated work requirements that previously were
completed by a number of contractors. Nevertheless, incumbent contractors
generally completed a major portion of the work.

Comments From the General Services

Appendi x II I Administration Note: GAO comments supplementing those in the
report text appear at the end of this appendix.

See comment 1. See comment 2.

The following is GAO's comments on GSA's letter dated November 9, 2000. GAO
Comments 1. We changed the report title.

2. This statement has been deleted from the report.

Comments From the Office of Federal

Appendi x V I Procurement Policy

Appendi x V

GAO Contacts and Staff Acknowledgments GAO Contacts David E. Cooper (202)
512- 4841 Ralph Dawn (202) 512- 4544 Acknowledgments In addition to those
named above, Ken Graffam, Russ Reiter, Jeffrey Rose,

Tom Taydus, and John Van Schaik made key contributions to this report.

(707460) Lett er

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Appendix I

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Appendix II

Appendix II Information on Selected Orders

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Appendix III

Appendix III Comments From the General Services Administration

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Appendix III Comments From the General Services Administration

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Appendix III Comments From the General Services Administration

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Appendix IV

Appendix IV Comments From the Office of Federal Procurement Policy

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