Overview of the Executive Order
The proposed GWAC consolidation plan to be moved under GSA is the most significant federal purchasing change in over a decade. The main feature of the plan is the combining of the buying of common goods and services under GSA’s management. Currently, mostly all federal government agencies operate their own respective contract vehicles, that they themselves set up, manage and operate similar to how GSA does the same with their contract vehicles. The intent is to consolidate all contract vehicles under one agency ‑ GSA.
The effectiveness of the plan mostly relies on the GSA utilizing their existing tools, knowledge, and market power. The aim is to make purchases of goods and services from the private sector more efficient and benefit not only the government agencies but also conserve taxpayer dollars
The expected benefits of the plan are:
- Cost savings: By consolidating procurement, the government expects to reduce redundant spending and negotiate better bulk pricing.
- Increased efficiency: Centralized purchasing is intended to streamline acquisition processes and improve contract management.
- Greater standardization: Agencies will follow uniform procurement standards, improving accountability and transparency.
- Reduction of contract duplication: The executive order aims to prevent agencies from running separate contracts for the same goods/services.
Proposed Geographic Scope and Definition of Common Goods and Services
The two key phrases used in the Executive Order affecting the proposed consolidation are “common goods and services” and a “domestic” geographic scope.
Prior to this Executive Order, The Category Management Leadership Council under the Office of Management and Budget (OMB) had defined what Category Management of “common goods and services” these ten (10) procurements categories:
- Information Technology
- Professional Services
- Security and Protection
- Facilities and Construction
- Industrial Products and Services
- Office Management
- Transportation and Logistics
- Travel Human Capital
- Medical Supplies and Services
The geographic limitation of the Executive Order’s phrase “domestic” would this plan only to federal agencies whose mission objectives and operations that are not inclusive of international support from its contract vehicles in the procurement process.
Implementation Plan and Agency Responsibilities
As if the plan was not transformative enough, the schedule for its implementation by any measure is aggressive. Adding to challenge, it is potentially scheduled to take place during the busiest buying season of the federal government’s fiscal year.
Here are the finer points of the plan’s schedule:
- Agencies must submit transition plans to GSA within 60 days (by May 19, 2025).
- GSA must develop a full procurement consolidation plan within 90 days (by June 18, 2025).
- Agencies will be required to use GSA contracts instead of their own for common goods and services.
Impact on Federal Agency Operations
Agencies currently using GWACs—like NASA’s SEWP, NIH’s CIO-SP3 or Army’s CHESS —may be forced to shift to having GSA manage its contracts.
Relinquishing contract of the procurement process and management of its own contracts will be a drastic and unexpected change for the Agency Heads effected by the plan. Contracts that don’t fit into GSA’s structure may face delays or cancellation.
Government contractors that are integral interwoven in the operations within the affected agencies will need to adjust to new GSA procurement standards. Undoubtedly, implementing this plan while accomplishing the mission objective for each agency will be a challenge both the agency personnel as well and the federal contractors supporting them.
Concerns and Potential Drawbacks
Critics of the proposed plan argue that centralization may limit vendor competition and discourage new, innovative solutions from emerging. Federal agencies often set aside contracts for small businesses—consolidation could reduce these opportunities. Large-scale GSA contracts might favor larger firms, making it harder for smaller businesses to compete.
Agencies that previously managed their own procurement (e.g., NASA, NIH, Army, Navy) may lose control over procurement process decision-making. The shift to GSA procurement could slow down specialized or urgent purchases unique to each agency.
Supporters (typically large contractors and procurement efficiency advocates) believe this move will drive cost savings and improve federal spending transparency.
Critics (especially small business owners and agencies with specialized needs) argue that it could stifle competition, limit innovation, and complicate procurement for non-standardized needs.
The Projected Road Ahead
Executive Orders from the desk of the President are often challenged by federal agencies, or the parties affected seek to modify or exempt themselves. The expectation is that this Executive Order will be no different. Agencies accustomed to using their own contract vehicles will most certainly resist this consolidation effort.
Agencies with an international mission objective will certainly seek refuge under the geographic scope of the Executive Order covering only federal agencies with domestic operations.
Other agencies that have specialized mission objectives will argue that their unique procurement requirements are outside of the realm of “common goods and services”.
For any federal agency to quadruple its size in a relatively short period of time, it usually only occurs under extreme circumstances. An unexpected incident that leads to the mobilizing of military forces is an example taken from the history our procurement system. Questions remain about whether GSA has the capacity to handle the increased volume of procurement under its control.
In summary, it may very well turn out that this Executive Order may be implemented but may not have the expected widespread coverage among all federal agencies, due to well defined requests for exemptions by the very same agencies that the Executive Order targets.
Recommendations for Small Businesses
- The GSA MAS is a safe haven from the proposed changes. It is also the most widely used and most familiar to all federal agencies, having been in existence since 1994. As we approach the government buying season that extends through September 30th, having a strategically designed and densely populated GSA MAS contract with services, solutions and products will allow any federal agency to access without any interruption by the proposed changes.
- Seek to establish with your existing federal agency clients a BPA, BOA or IDIQ single award if possible or multiple award contract vehicles using the GSA MAS as a basis. This will allow for expedient and simplified procurement processes by your federal clients.
- Get onboard with the top 100 prime contractors by registering with them as a small business. If the proposed plan is adopted as expected, it will favor larger companies more than it will smaller firms. Subcontract opportunities from the larger firms will increase dramatically as a result. Also be sure to register with the federal agencies themselves and track their Acquisition Forecasts for prime contract opportunities.
