Contractor Group Opposes Cascading Procurements The Professional Services Council is calling for sharp restrictions on cascading procurements, saying they cause companies to spend money developing proposals that may never even be considered. “Cascading appears to be primarily a tool of convenience for agencies to determine whether certain types of firms are capable of performing a given requirement, but it is a poor proxy for the required market research,” PSC President Stan Soloway wrote in a July 12 letter to David Safavian, administrator of the Office of Federal Procurement Policy. PSC is a contractor group with nearly 200 large, medium and small business members. In a cascading procurement, all offerors submit their proposals at the same time and the customer agency first considers, for example, proposals from 8(a) and HUBZone firms, then other small businesses, then large businesses. When a winning proposal is identified, the other offers further down the cascade are not considered. “As such, it is entirely possible that the vast majority of companies that have expended precious bid and proposal money to develop their submittals will never be evaluated,” Soloway wrote. “This is a fundamental departure from the longstanding and fundamental procurement practice under which all bidders are evaluated fairly, at the same time and on the same evaluation criteria.” “I am aware of no company, large or small, that supports cascading,” he added. In a separate letter, PSC urged the Health Resources and Services Administration to cancel a current RFP that is being competed as a cascade. The solicitation for several indefinite delivery, indefinite quantity contracts to provide professional services states that offers will be evaluated in a two-tier cascade, small businesses followed by large businesses. PSC urged the agency to set aside some of the awards if its market research shows that qualified small firms are available. Cascading procurements are a recent development. Advocates say they save time because if an agency advertises a traditional set-aside, but receives no satisfactory offers, it must start over with a new solicitation. The General Accounting Office upheld the use of cascades in a 2002 case involving the Department of Housing and Urban Development. In denying a bid protest, GAO said. “The cascading set-aside preference provision used in the RFP here reasonably put large businesses on notice that, if the agency receives a sufficient number of eligible small business offers, large business proposals received simply would not be considered for award.” (SAA, 8/23/02) The case was Carriage Abstract, Inc., B-290676; B-290676.2.