Pentagon moves to implement ‘Anything-as-a-Service’ pilot program

The Defense Department has identified an initial set of product and service codes that it will target for a new “Anything-as-a-Service” pilot program.

Congress directed the establishment of the pilot in the fiscal 2024 National Defense Authorization Act to explore the use of “consumption-based” contracting.

In the conference report on the legislation, lawmakers defined “Anything-as-a-Service” as a model “under which a technology-supported capability is provided to the Department of Defense and may utilize any combination of software, hardware or equipment, data, and labor or services that provides a capability that is metered and billed based on actual usage at fixed price units.”

A key purpose of the effort is for officials to measure the cost and speed of delivery in comparison to using other buying processes at the regular intervals that are customary for the type of solution provided.

The Trump administration is now moving forward with implementation. The Defense Pricing, Contracting, and Acquisition Policy (DPCAP) directorate recently announced the establishment of the pilot program “to promote greater use of ‘Anything-as-a-Service’ as a concept to fulfill DoD mission requirements under FAR-based contracts or Other Transaction agreements.”

A May 1 memo from John Tenaglia, principal director of DPCAP, implemented statutory authority to employ the model “targeting an initial set of Product and Service Codes (PSCs) for Software-as-a-Service (SaaS), Data-as-a-Service (DaaS), and Space-as-a-Service (facility, including classified space as a service).”

For SaaS, that includes Business Application/Application Development Software as a Service, DA10; Compute as a Service: Mainframe/Servers, DB10; Data Center as a Service, DC10; End User as a Service: Help Desk, DE10; IT Management as a Service, DF10; Network as a Service, DG10; Security and Compliance as a Service DJ10; and Storage as a Service, DK10, according to an attachment to the memo.

DaaS includes Data Center Support Services, DC01; Mobile Device as a Service, DE11; Network: Satellite Communications and Telecom Access Service, DG11; Platform as a Service: Database, Mainframe, Middleware, DH10; Information Retrieval, R612; and Data Collection Services, R702; Special Studies/Analysis-Scientific Data, B529; and Special Studies/Analysis-Scientific Data (Other Than Scientific), B506.

For space-as-a-service, that includes Rental of Office Buildings, X1AA; Rental of Conference Space and Facilities, X1AB; and Rental of Other Administrative Facilities and Service Buildings, X1AZ.

DPCAP officials “will consider contracting officer proposals to include additional PSCs,” Tenaglia noted.

The memorandum was sent to the commander and acquisition executives of Cyber Command, Special Operations Command and Transportation Command, as well as the deputy assistant secretary of the Army for procurement, deputy assistant secretary of the Navy for procurement, deputy assistant secretary of the Air Force for contracting, and defense agency and DOD field activity directors.

Contracts accepted into the pilot can be exempted from certain requirements related to certified cost or pricing data and full and open competition.

To participate in the program, contracting officers must request approval from DPCAP.

If given the green light, contracting officers “shall, to the extent practicable, enter into a contract or other agreement under the pilot program within 100 days of synopsizing the contract action or posting the justification,” Tenaglia wrote.