GW Law Faculty Publications & Other Works

Document Type

Article

Publication Date

2026

Status

Accepted

Abstract

The General Services Administration’s OneGov initiative offers federal agencies access to leading AI platforms—including ChatGPT, Claude, Gemini, Grok, Copilot, and Perplexity—at promotional prices ranging from free to one dollar per agency. This Feature Comment examines how these nominal price points function as the procurement equivalent of loss-leader pricing: low enough to accelerate adoption while obscuring lifecycle costs, operational dependency, and diminished negotiating leverage at renewal. Drawing on the Federal Acquisition Regulation’s buying-in framework (FAR 3.501), switching-cost theory, and publicly available reseller pricing data, the Comment demonstrates that the gap between promotional and post-promotional pricing can be substantial—and that most renewal terms are not publicly disclosed. It analyzes how behavioral and organizational lock-in develops during promotional periods through workflow integration, institutional habit formation, and the erosion of in-house capacity, and explains why exit rights not secured before adoption are difficult to negotiate afterward. The Comment identifies transparency and governance gaps in the current OneGov structure and proposes a risk mitigation framework organized at the contract, operational, and program levels—including binding post-promotional pricing, structured pilot constraints, dependency tracking, and uniform public disclosure of lifecycle terms as a condition of OneGov participation.

GW Paper Series

2026-23

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