Over the decades, the General Services Administration (GSA) has used different terms, including assessments, audits and reviews, to describe how it determines whether a company is compliant with the GSA terms and conditions. For the purposes of this article, we’ll use the word assessment. The criteria of an assessment, an audit and a review are very similar, although there have been some nuances and slight variations in emphasis throughout the years.
Regardless of when a company received its GSA Schedule and where it is in the term of the contract (base period, option period, etc.), it is never too early to ensure compliance. Here are some things to think about:
Reporting sales
- Has the Industrial Funding Fee been paid on a timely basis? The IFF is due 30 days following the end of each quarter (Jan. 30, April 30, July 30 and Oct. 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. Ideally, there is a fail-safe process that is incorporated. Somewhat surprisingly, if a company overpays the IFF (including the IFF on travel), this is also regarded unfavorably.
- Have all invoices that are based on the GSA Schedule been reported? Another issue that the GSA occasionally discovers is that a company has a contract based on the GSA Schedule but does not include it when the IFF is calculated. Regardless of whether they are inadvertent, 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 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 Favored Customer (Basis of Award) client at a lower price than the GSA Schedule rates? The GSA expects companies to consider the GSA its most favored customer; selling to Basis of Award clients at a lower price than GSA customers may cause a compliance issue. The GSA contract point of contact must be notified as soon as possible but no later than 15 calendar days after the price reduction to Basis of Award clients that affected the pricing relationship with the GSA.
Labor categories
- Does each person meet the qualifications for their assigned labor category? The labor qualification requirements apply to both the GSA Schedule holder and its subcontractors. The GSA will likely request a significant sample of resumes to determine whether qualifications are met. The GSA may ask the company how it tracks and confirms qualifications for each person. Ideally, there should be 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 case in which the contracting officer cannot make an exception to waive requirements that would allow the contractor to invoice at a higher rate than the one for which the person is qualified.
Other factors
- Did the contractor discount prices to the government? (The prices 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 price list requirements?
- Did the contractor deliver on time?
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