Over the decades, GSA has used different terms to describe how they determine whether a company is compliant with the GSA Terms and Conditions including assessments, reviews, and audits. I will use the term “Assessment” for my article. The criteria are very similar, although there have been some nuances and slight variations of emphasis throughout the years. Regardless of when the company received their GSA Schedule and where it is in the contract life cycle (Base Period, Option Period, etc.), it is never too early to ensure compliance.
Reporting Sales
• Has the Industrial Funding Fee (IFF) been paid on a timely basis? The IFF is due 30 days following the end of each quarter (January 30, April 30, July 30, and October 30). Regardless of whether the company owes any money, the reporting deadline remains.
• Has the company paid the accurate amount for the IFF? What system(s) are used; accounting software, a manual method, or both? There is not a single correct answer; however, the Government wants the company to explain how work purchased through the GSA is segregated to ensure correct payment. Somewhat surprisingly, if a company overpays the IFF (e.g., including IFF on travel), this is also regarded unfavorably.
• Are all invoices that are based on a GSA Schedule been reported? Another issue that GSA occasionally discovers is a company has a contract based on the GSA Schedule, but does not include it when the IFF is calculated. Regardless of whether it is inadvertent or not, the Government has little tolerance for errors.
Pricing Compliance
• Were the labor categories priced in accordance with the GSA Schedule? Overbilling Schedule customers for unqualified employees is a common finding of the GSA Assessments.
• Does your company know the Basis of Award for its GSA Schedule? Has the company sold its products or services to a Most Favorite Customer client (Basis of Award) at a lower price than the GSA Schedule rates? GSA expects the companies to consider GSA as its most favorite customer; selling to Basis of Award clients at a lower price than GSA customers may cause a compliance issue. The GSA Contract POC must be notified as soon as possible but no later than 15 calendar days, after price reduction to Basis of Award clients affecting the pricing relationship with the GSA.
Labor Categories
• Does each person meet the qualifications for their assigned labor category? The labor qualification requirement applies to both the GSA Schedule holder and its subcontractors. GSA will likely request a significant sample of resumes to determine if qualifications are met. GSA may ask the company how it tracks and confirms qualifications for each person. Ideally, there is a system in place. There can be significant penalties if a company invoices for a labor category in which the employee does not qualify. This is one example where the Contracting Officer cannot make an exception to waive requirements that would allow the Contractor to invoice at a higher rate than the qualifications the person meets.
Other Factors
• Did the Contractor discount prices to the Government? (The prices listed on GSA Schedules are ceiling rates and therefore, the Government expects discounts.)
• Did the Government demonstrate compliance with GSA Advantage requirements?
• Did the Contractor demonstrate compliance with the contract promotion requirements (use of GSA logo and posting on website)?
• Did the contractor demonstrate compliance with the Pricelist Requirements?
• Did the Contractor deliver on-time?
If the company can answer these questions affirmatively, then the company is on the right track to receiving a positive GSA Assessment.
If you have a GSA Schedule and need assistance with managing your orders or other contracts, please contact Karen Long at Klong@StreamlineGovCon.com or 240-644-5314
If you want to submit a proposal for a GSA Schedule, please also contact us.
We are happy to provide referrals to companies who provide this service.