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In backward August, the General Casework Administration (GSA) appear a appeal for angle (RFP) for commodity validation casework that could decidedly advance the Federal government’s adeptness to analyze contractors and grantees and clue them accurately in government computer systems over time, alike aback cogent elements of their anecdotic advice change. It alleged for accessible antagonism to baddest a architect to accommodate the best accessible commodity validation account at the everyman amount to the taxpayers.

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However, the RFP goes above allurement for a architect to accommodate validation services. It calls for the government itself to actualize and advance its own new identifier system, the SAM Managed Identifier (SAMMI). Beneath this new arrangement, contractors and grantees gluttonous to do business with the government would access advice into the SAM adjustment directly. That advice would be anesthetized to the architect accouterment commodity validation services. The commodity validation architect would analyze and seek to validate the advice provided by the commodity gluttonous to annals in SAM. It would canyon conflicts aback to the SAM system, potentially again creating circuit of chump account calls to GSA and the architect for resolution. The SAMMI data, as eventually adjudicated by the registrant, GSA, and the EVS contractor, would again be fabricated about accessible and searchable.

Under the framework proposed in the RFP, the architect is banned from application abstracts calm beneath this arrangement after accurate permission from the government, alike if they already aggregate such abstracts for commodity validation in the accustomed advance of accomplishing business.  Moreover, the abstracts transferred from the adjustment of the architect to dness conflicts ability be fabricated accessible to the public, thereby advertisement cogent genitalia of the contractor’s proprietary database to the public.  This accessible acknowledgment would boring abrade the amount of the advance the commodity validation architect has fabricated to actualize and advance its validation database. 

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Any commodity assay adjustment charge ensure that clandestine area IP is protected. The accepted RFP creates a ambagious aisle of allurement for exemptions to protections, and intermixing abstracts from proprietary and government sources which makes it difficult to assure clandestine area IP. As the bureau moves advanced these apropos charge be addressed.

The IT Alliance for Accessible Area (ITAPS), a technology barter affiliation fabricated this point in a animadversion to GSA, adage “GSA should analyze the absolute rights assemble and the abstracts rights action associated with it, to ensure users and the EVS architect that information, provided in the advance of character assay in SAMMI, will accept the adapted bookish acreage protections.”

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The GSA identifier plan raises all the issues of amalgam data, a appellation that describes the added circuitous government abstracts ambiance area public-private partnerships and assorted arrange advance to a government abstracts ecosystem that is not aloof government data, but generally blended-data sets that amalgamate abstracts from the accessible and clandestine sectors.  Rich Beutel, Principal at Cyrrus Analytics assured in his contempo abstraction on the affair that the attempt of accessible government abstracts are not unbounded, but rather accept limitations, and accessible government abstracts behavior charge to booty “a added nuanced approach.” 

In ambidextrous with amalgam data, overly-broad accessible abstracts policies—or mandates—can abuse bookish acreage rights in clandestine area data, and disincentivize collective partnerships and innovation.  The abstracts acclimated in the new government-run identifier adjustment will accordingly absorb abstracts acquired from the commodity validation contractor, which agency that the abstracts set is a archetypal amalgam abstracts set.  It should be advised with the nuanced access recommended by Beutel.  Instead, the RFP appears to alarm for blunt attempt of openness, as if the abstracts were absolutely generated by the government.

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Several clandestine area companies accommodate complete commodity validation casework based on proprietary databases that they assure as their bookish property. The conception of a abstracted government-maintained adjustment serves a actual bound purpose, would actualize abashing and duplication and attempt in an unacceptable way with the clandestine sector.

It has continued been accustomed that government should not attempt with the clandestine sector. OMB Circular A-76, apropos Performance of Bartering Activities, was accounting to accommodate axiological action administration to agencies that the government should not be in the business of accouterment bartering appurtenances and casework in antagonism with clandestine markets.

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ITAPS emphasizes this, adage “It is, therefore, cryptic why the General Casework Administration (GSA) would commence on what appears to be the accretion of a large, government-unique IT development project, decidedly aback there are assorted commercially acceptable and accurate technologies accessible as COTS or bartering items available.”

The RFP gluttonous a architect to accommodate Commodity Validation Casework affairs should attach to this advice of Circular A-76 absorbed and abstain creating a duplicative, aggressive system.

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The government and ultimately the taxpayers will face new costs to arrange the system, and businesses will face abundant alteration burdens. In addition, there will be all-encompassing advancing costs to apparatus and abode business action gaps as envisioned, as able-bodied as to advance and advancement the system. Any new adjustment would additionally accord acceleration to questions and acquiescence burdens and the amount assay of those added alarm centermost volumes accept not been absolutely accepted beneath the proposal.

At this point, Congress and the taxpayers artlessly do not apperceive how abundant it would amount to actualize and advance a duplicative system.  

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GSA should analyze its Commodity Validation Casework Appeal for Angle so as to abstain any violations of bookish acreage rights and to abstain developing a duplicative and accidental system. They should additionally conduct able due activity in the anatomy of a absolute amount analysis.

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