Comment Submitted by Peter G. Tuttle, Distributed Solutions, Inc.

Distributed Solutions, Inc. (DSI), a small software company who provides acquisition management solutions to federal clients, fully supports the intent of this interim rule to enhance competitive opportunities and reduce organizational conflicts of interest by limiting specified lead system integrator (LSI) participation in major acquisitions. DSI applauds the Department in taking this step. We do recommend, however, that the final rule be clarified to ensure that the purchase of LSI services for the DHS from GWAC, FSS, MAC or Interagency Agreements is also specifically included, so that there is consistency throughout the Department in executing this policy. The rationale for this suggestion is that no matter which contractual vehicle is used by Departmental Contracting Officials, or if purchasing of LSI services is conducted for the Department by other entities (e.g. assisting agencies, like GSA, NASA SEWP, etc.), the DHS policy regarding the use of lead systems integrators is followed and cannot be selectively bypassed.