EIS 101: September Deadline Approaches for Agencies

With summer coming to a close and back-to-school season approaching, agencies will need to catch up on their assignment to get task orders in for the next generation of telecommunications contracts – Enterprise Infrastructure Solutions, or EIS. With a September 30 deadline fast approaching, did the class of Federal agencies do their homework on the contract? Current indicators show some progress, but a long way to go.

After fits and starts marked by extensions for Federal agencies of the deadline to move on from their existing communications services contract, the EIS contract – worth $50 billion over ten years – is a key part of how government hopes to not just refresh, but overhaul and modernize its telecommunications, networks, cloud and more. For those plugged into networking, EIS represents a major shift in how Federal agencies acquire their communications technology.

If the news of agencies moving slowly to meet deadlines on EIS sounds familiar, you’re not wrong – only 13 agencies made the March 31 deadline to release contract solicitations. But telecommunications contracts have a long history of delays, one that the General Services Administration (GSA) is fighting hard to change. While early deadlines may not be do-or-die, agencies need to keep their eyes on May 2023 – the date EIS will replace all existing telecoms contracts.

With that four-year horizon for agencies to get on the EIS contract fixed in place, it makes sense to take a step back, look at how the contract got to this point, and look towards how it will likely play out.

A Brief Overview

The EIS contract is the successor to several giant networking contracts of the past, like FTS-2001 and Networx. Announced in 2015, EIS supports 12 defined areas under the contract.

  • Data Service
  • Voice Service
  • Contact Center Service
  • Colocated Hosting Service
  • Cloud Service
  • Wireless Service
  • Commercial Satellite Communications Service
  • Managed Services
  • Access Arrangements
  • Service Related Equipment
  • Service Related Labor
  • Cable and Wiring

With nine prime contractors, including three small businesses, the contract aims to offer competitive pricing and different options for agencies to select from. Agencies will release solicitations to vendors, and award task orders for service instead of going through a long and time-consuming full acquisition cycle.

Why EIS?

The strategy behind the EIS contract is more than a simple replacement. While the older contracts expire, and agencies benefit from new competition from the market, GSA is aiming to put network modernization front and center.

“The way that this contract is priced is for those future technologies,” said Bill Zielinski, acting assistant commissioner for the Office of Information Technology Category at GSA, last month. “As we move forward to the new technologies, you see the beneficial pricing is in and around the new set of technologies, and it actually becomes less beneficial to do the like-for-like.”

Just as importantly, EIS offers a wider view of the network, with more options for services.

“Agencies and industry recognize that the GSA EIS contract’s ‘scope’ is much broader than its predecessor Networx and FTS contracts and, as such, EIS can embrace support activities which would not have been available under prior contracts,” notes a recent report from ACT-IAC.

One example of where EIS can help is in implementing a zero-trust model at agencies. ACT-IAC’s recent report on zero-trust technologies in the Federal government notes that the government “has a unique opportunity to capitalize on the confluence of IT modernization and EIS transition to profoundly transform agencies’ network service delivery and data protection.”

Another example is software defined wide area network (SD-WAN), which one vendor noted that it plans to provide under EIS, offering easier management of the network.

So Why the Delay in Adoption?

In response to feedback from agencies and industry, GSA held the transition plan to EIS steady, but in December 2018, pushed back the deadline for moving off the existing Networx contract, as well as WITS and local service agreements from the original deadline of May 2020, to the current expiration of May 2023.

“Extending the existing legacy contracts provides agencies with additional time to transition and modernize in one step,” said Alan Thomas, FAS Commissioner, in a blog post.

The delay did not come as a surprise – agencies and industry had expressed their concerns over the 2020 deadline. What caused the delay?

“I think the challenge is twofold – one, agencies were not ready. They didn’t have the funding for this, or they felt they didn’t have the funding or set it aside, they were busy meeting other day-to-day needs. The second thing is, I think a lot of agencies were pretty happy with the telecommunications solutions they have now, either because they work for them or they really just don’t know what the state of the art or the state of the market is today,” said Larry Allen, president of Allen Federal Business Partners, on a December 2018 episode of Government Matters TV.

Agencies have also brought up other concerns with moving to EIS amid other policy changes, such as the Trusted Internet Connections (TIC) 3.0 policy. While a draft was released in December 2018, some agencies may still be waiting to see how it will affect their networking strategy.

Another issue has been vendors not having the authority to operate – the extensive security testing from GSA has caused some delays in when vendors can begin work, and many of the smaller contractors are still working through the process to get approval.

However, GSA has been adamant that the extension is not about letting agencies procrastinate on EIS.

“That extension window, to May of 2023, isn’t to allow for the front end of this to slide out, but to really allow for that time that’s really necessary to modernize and incorporate the new elements of the contract, and do so in a mindful way,” said Zielinski.

A Watchful Eye From the Hill

The delay in completing the move to EIS is attracting some attention from Congress as well.

Rep. Gerry Connolly, D-Va., chairman of the House Oversight and Reform Committee’s Government Operations Subcommittee and a strong advocate for Federal IT issues on the Hill, has been willing to push agencies to adopt IT modernization initiatives before. For instance, pressure from Rep. Connolly and his then-committee mate Will Hurd, R-Texas, pushed the White House to clarify the role of IT working capital funds at agencies in the White House’s FY 2020 budget.

Connolly told MeriTalk in April that he’s also willing to push agencies to the finish line on EIS.

“We know that the transition to EIS is already delayed at the request of several agencies who were not able to meet the original transition deadline of May 2020, and I am concerned about that,” Connolly said. “I plan to continue our oversight of this transition and help agencies avoid continued cost overruns associated with extending Networx and delaying transition to EIS.”

EIS has also attracted attention from the House Appropriations Committee, which drafted a funding bill for GSA that includes the requirement for a Government Accountability Office (GAO) report, an updated transition plan, and an updated timeline.

“While the Committee understands the challenges Federal agencies face transitioning telecommunication services from one set of contracts to another, the Committee believes it is important for the GSA to effectively apply lessons learned from prior transitions,” the bill notes.

Living in the Shadow of Networx

Speaking of Networx – while EIS holds a lot of promise for agencies and IT modernization, it also faces a battle for adoption that parallels the main contract it’s replacing.

Networx, initiated in 2003 to replace the FTS2001 program, awarded the contract to five vendors in 2007. However, the transition to Networx also was delayed, with agencies slow to make the transition to the new contract. As a result, GSA was forced to keep legacy contracts open past the planned dates of 2006 and 2007 until March 2013. That delay warranted a report from GAO, which found that the wait led to an increased cost of $66.4 million, and excessive spending on old contracts to the tune of $329 million.

“In particular, the complex Networx acquisition process compounded by a reported lack of telecommunications and contracting expertise within the agencies contributed to delays,” GAO’s report states.

With GSA extending the lifespan of the Networx contract from 2020 to 2023, concerns about the transition to EIS are drawing unfavorable comparisons.

However, GSA is making a strong push for agencies to make the transition in a timely manner, and encouraging agencies to bring their questions forward now.

Slow Progress on Solicitations, but Momentum Building

While GSA is keeping to its deadlines on EIS, Federal agencies continue to lag behind expected progress.

With a deadline to have agency solicitations on the EIS contract in by the end of March, only 13 agencies had released 18 solicitations on the contract by then. However, the deadline was not the end of the process – agencies still have time to catch up and get their solicitations in.

“It is highly recommended that agencies release their solicitation packages as soon as possible so that upon completion of the source selection process, they will have enough time left on their existing contract to implement their awarded solution,” a GSA spokesperson told MeriTalk in April.

GSA also said it received 39 solicitations for scope review in total, and expected to get 30 more by the end of April.

NASA was first out of the blocks when it awarded the first task order on the EIS contract in April, with the Department of Justice following with a nearly $1 billion task order in July.

“We’re starting to see that momentum pick up and build,” said Zielinski.

Vendors Making Progress as Well

Right now, EIS is still in its early days, but progress around the contract is ramping up.

One of the milestones currently in progress is the process of vendors getting authority to operate. As part of the contract, the nine vendors are subject to a very thorough audit to ensure authorization at the moderate level. Applying the Federal Information Security Modernization Act (FISMA) framework to industry, companies need to remedy any issues and ensure that their business support systems are secure to begin work on the contract, though agencies can still issue awards to vendors waiting for ATOs.

Currently, three of the largest vendors – AT&T, CenturyLink, and Verizon – have received ATOs, and GSA has stated it expects more vendors to gain ATOs in the near future. The most recent update from GSA in August found the remaining vendors very close, ranging from 78 percent to 91 percent through the authorization process, bringing EIS’s full cohort on contractors close to ready.

While vendors are working through the process, agencies don’t have to wait. All vendors on the contract are able to bid, and with three vendors already approved to begin work, EIS is open and ready for business.

The Road Ahead for EIS

While many uncertainties remain for EIS, the future for the contract looks promising – as long as agencies get moving.

One thing that is certain – GSA will continue to push agencies and industry forward. With a clearly defined roadmap for agencies, GSA is working to make sure there is no need for another delay. The remaining milestones set by GSA are:

  • On March 31, 2020, GSA will limit the use of extended contracts for agencies who have not made task order awards on EIS;
  • On March 31, 2021, GSA expects agencies to have 90 percent of their telecom inventory off of legacy contracts and moved to EIS; and
  • On May 31, 2023, Networx, WTIS, and local service agreement contracts will expire and be fully replaced by EIS.

Will agencies meet those deadlines? It’s impossible to predict with certainty, but the impact from agencies delaying their solicitations could continue on, impacting the transition to EIS in the long-run.

On the flip side, the transition could go more quickly than expected if all goes well. GSA has pointed out that the extension on Networx and WITS is only until 2021, with two optional years following. While conventional wisdom says that agencies will take full advantage of the three-year period, a successful transition could see those contracts retired earlier than expected.

Agencies can also expect some pressure from Congress, with Rep. Connolly promising to provide oversight over EIS. Hearings may be on the way, and may serve as the impetus agencies need to get moving on their contract migrations.

Throughout it all, agencies need to be thinking about how they modernize networks for the next ten years. Like-for-like replacements are not going to cut it in the long run – innovative technologies like SD-WAN, zero trust, and 5G will become ubiquitous during the lifespan of the EIS contract, and agencies will need to be ready.

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