Important Facts Concerning What Is Included in the GSA Schedule Application

Under the new GSA IOA visits policy it is important to understand the areas of focus for GSA:

Preparation and Prevention is Key:

Areas of Focus:

Sales Reporting (IFF)

This has been a staple of IOA visits so no expected change to approach of checking 72A reports against sales figures.

Do expect the IOA to ask to see the system and if you have a written policy in place for this.

Pricing/Basis of Award Monitoring

Although this was listed on earlier report cards this is the new focus of the changes.

IOAs will focus on sampling commercial rate transactions from a specific time period

Invoices or System Transactions

A BOA/MFC pricing policy and process is required and should be in place. The IOA will most likely ask to see the policy if the sample turns up any type of potential Price Reduction Clause rate issue.

Unless Specifically Disclosed under the CSP-1 in the deviations and concessions section the GSA Schedule holder cannot offer lower rates commercial to a category or class of customers who are their BOA.

All Commercial Customers means everyone (sub to a prime etc.)

As a GSA Schedule holder it is your responsibility to understand and adhere to the regulations.

Reasons Why Companies Need GSA Schedule Consultants

Compliance is the key reason why companies should look to hire reputable GSA Schedule consultants.  Here are some quick hits with regards to GSA Schedule compliance that should always be followed:

Preparation and Prevention is Key:

•    Polices and Processes should be implemented for your GSA Schedules.

•    BOA/MFC/PRC/IFF and LCAT mapping should be in place at a minimum.

•    Make Sure you are Mapping Your Labor Categories Correctly and not backing in rates when you build your price.

•  Make sure each employee you map meets the minimum requirements of the Labor Category Proposed

•  Make sure you are tracking your Basis of Award Customer and that you are not selling your Labor Categories at a lower price commercially then what's on your GSA Schedule

•  Yes… being a subcontractor to a prime contractor regardless of end user is a commercial transaction

As a GSA Schedule holder it is your responsibility to understand and adhere to the regulations.