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B-183079 1 (1979-03-07)

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                COMPTROLLZR GENERAL OF THE UNITED STATES
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B-183079                               MAR 71979


The Honorable Lawton Chiles
Chairman, Subcommittee on
  Federal Spending Practices
  and Open Government, Comrait-
  tee on Govermental Affairs
United States Senate

Dear Mr. Chairman:

     On February 7, 1979, you requested ourIcomments on a
proposed amendment to Senate bill 53 the Pediral Acquisi-
tion Ileform Act. The purpose of tho proposed amendment
(No. 54) is to perrdt firms other than architectural and
engineering firms to compete for certain jobs through
negotiated bidding procedures.

     The proposed amendment would extend the coverage of
40 U.S.C. Sec. 541 et s.. (1976) beyond the services
provided by professional architectural and engineering
firms. The statute defines these services as those pro-
fessional services of an architectural or engineering
nature as well as incidental services that members of
these professions and'those in their employ may logically
or justifiably perform.

     We do not look favorably on the proposed amendment for
two reasons.   First, we are not aware of any valid reasbns
why the statute should be amended to cover other than pro-
fessional architectural and engineering services. Secondly,
the procedures prescribed in the legislation preclude con-
sideration under any circumstance of price as a factor in
selecting an architectural and engineering firm. We see no
advantage to the Government allowinoj additional services to
be procured without being able to consider price as one
of the factors of the competitive negotiation procedure,
although we recognize that price may not be govprning in a
great majority of cases.

                               Sincerely yours,

                             (MGM$) ELMER B. STAATS

                               Comptroller General
                               of the United States

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