Bundling Strategy's Effectiveness Difficult to Measure: GAO General Accounting Office investigators say it will be difficult to judge the effectiveness of the Bush administration’s anti-bundling initiative because no metrics have been established to measure contract bundling or its impact on small businesses. In the first report on the highly touted initiative, GAO said the anti-bundling strategy has the potential to improve contracting opportunities for small firms, but it is too early to tell whether it is working. A rule issued last October requires agencies to explore alternatives to bundling and to provide written justification for any bundled contract above specific dollar amounts. It also requires bundling reviews and justifications for orders through GSA schedules and other multiple award contracts above the thresholds. GAO said only four agencies reported any bundled contracts during fiscal 2002, before the new rule took effect; just 24 contracts were identified as bundled. According to law, bundling is defined is a combination of existing contracts into a single large one that is unsuitable for small businesses; the definition does not cover new requirements that may be bundled into one contract. Critics of the administration strategy said it relies on SBA’s procurement center representatives and agency offices of small and disadvantaged business utilization to police unjustified bundling, but provides them with no new resources to carry out their responsibilities. There are fewer than four dozen procurement center representatives nationwide; the exact number is unclear. One PCR said some of those listed in SBA’s directory are retired or, in one case, dead. The GAO investigators said SBA has not yet implemented one key part of the anti-bundling strategy: creation of a best practices manual that agencies could use in training their acquisition personnel. GAO recommended that the Office of Management and Budget identify metrics to measure bundling and its impact. OMB said it sees no need for another layer of data reporting. OMB required the 23 largest agencies to file quarterly reports on their progress in combating unjustified bundling during fiscal 2003, but none of the reports was made public. The reports were discontinued last October. GAO’s report to the House Small Business Committee is number GAO-04-454, available at www.gao.gov.