It should not matter if you buy through EDI: Rules are rules

For more than two years, the government has been gearing up for electronic commerce.


The administration is a strong EC supporter, as reflected in the National Performance
Review. In response to White House prodding, the General Services Administration has
implemented a policy for progressive growth toward a paperless procurement system.


The Defense Department already had sought means to advance procurement efficiency and
effectiveness through industry/government automated techniques, most notably DOD's
Computer-Assisted Lifecycle Support program. But the focus of EC implementation today is
mostly on electronic data interchange.


The government is speeding toward electronic commerce through the use of EDI; some
agencies are far ahead of others in their shift away from paper. Arguably, DOD leads
agencies in applying EC, so to see its misapplication of some fundamental rules stands out
from what is expected of a leader.


In what appeared to have been an otherwise uncomplicated on-line procurement, the Army
drew a protest for its handling of a trivial issue. At issue was how agencies should
format the 13-character procurement solicitation number in using EDI.


Even the GSA Board of Contract Appeals differed in its opinions regarding the
application of standards addressing the format.


The Federal Acquisition Regulation specifies that hyphens should be included to
separate the different segments of the number, and so does a DOD requirement.


But hyphens aren't required for computers to recognize the segments. Why then, argued
the Army, should they be required if a solicitation is issued using EDI? A good point. But
a rule is a rule, stated one GSBCA judge, and military discipline and computer programs
are based on following rules.


Although it urged the Army to apply its rules, the board did not grant the protest,
primarily because the service had done nothing to prejudice the unsuccessful bidder
through the numbering snafu. And, GSBCA noted, other vendors found a way around the
identification problem by submitting a telecopy version of their proposals. In fact, so
did the protester.


But there's an underlying question raised by the protest: What can potential
contractors expect from electronic commerce if an agency misapplies standards published by
the government?


If different government authorities can't agree how to develop and apply data format
standards when converting from manual systems to electronic commerce, it shouldn't come as
a surprise that the procurement process has been so slow in evolving from paper. Perhaps
the members of the FAR Council should consider this dilemma in their rewrite process.



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