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Checklist for GSA Construction Contract Compliance

Checklist for GSA Construction Contract Compliance
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Managing a GSA construction contract can feel overwhelming, but a clear plan simplifies the process. This checklist covers everything you need to stay compliant and avoid mistakes:

  • Before the award: Register on SAM.gov, get your UEI, and review key rules like FAR Parts 8, 13, and 15.
  • After the award: Update contract info in GSA systems, assign roles (like a Contract Administrator), and ensure accurate data in GSA Advantage!.
  • Ongoing tasks: Submit sales reports, handle modifications, and maintain detailed records.
  • Construction-specific rules: Follow Davis-Bacon Act wage rules, submit certified payrolls, and monitor subcontractor compliance.
  • Stay organized: Use compliance software, automated reminders, and a digital repository for documents.

Getting Ready for Contract Award

SAM.gov Registration and UEI Setup

To get started, register your entity on SAM.gov. This step is crucial for validating your business and obtaining a Unique Entity Identifier (UEI).

  • Provide key documents like your Articles of Incorporation, Employer Identification Number (EIN), and banking information to complete the validation process.
  • Once you have your UEI, make sure to include it in all federal applications and contract-related actions.

FAR and GSA Rules Overview

Familiarize yourself with the Federal Acquisition Regulation (FAR), specifically Parts 8, 13, and 15, as well as GSA Schedule policies. These outline essential pricing, compliance, and reporting requirements.

After reviewing these rules, gather the necessary documents (details in the next section) to ensure you’re fully prepared.

Government Contracting – Compliance Check List For New …

First Steps After Contract Award

Now that you’ve reviewed the FAR and your Schedule, it’s time to handle the key tasks needed to set up effective contract management.

GSA Advantage! Data Entry

Avoid catalog errors and pricing issues by ensuring:

  • Your product or service data matches the awarded SINs (Special Item Numbers), including detailed descriptions, accurate pricing, and delivery terms.
  • Every line item aligns with your awarded Schedule categories and approved pricing.

Updating GSA System Information

Keep your contract records accurate by:

  • Updating essential details in GSA systems, such as:
    • Points of contact (Contract Administrator, Alternate)
    • Banking and payment details
    • Business address and contact information
  • Reviewing and updating this information quarterly or whenever changes occur.

Assigning Team Roles

Clearly defining responsibilities helps ensure compliance and smooth operations. Key roles include:

  • Contract Administrator: Manages contract updates, modifications, and system maintenance.
  • Compliance Officer: Monitors regulatory adherence and internal controls.
  • Financial Manager: Handles sales reporting, IFF payments, and ensures billing accuracy.

Once these steps are completed, you’ll be ready to focus on ongoing contract management to maintain compliance and performance.

Regular Contract Management Tasks

Staying compliant with GSA construction contracts requires consistent attention to key administrative duties. Here are some recurring tasks to manage effectively:

  • Submit Sales Reports and Fees: Follow the contract schedule to file sales reports, calculate and pay the Industrial Funding Fee (IFF), and keep detailed transaction records for audits. Use calendar reminders to ensure deadlines aren’t missed.
  • Handle GSA Modifications: Review modifications as soon as they’re issued. Accept or reject them within the specified timeframe, update your contract records, notify your team, and track all reporting requirements, due dates, submission portals, and responsibilities using a shared compliance calendar. Assign backups for added security.
  • Organize Critical Documentation: Use a contract management system to store wage determinations, certified payroll, and subcontractor payment verifications. Set up automated alerts to stay ahead of upcoming deadlines.
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Construction Contract Requirements

Once you’ve established routine contract management, it’s time to address the specific requirements tied to construction contracts. These add an extra layer to your sales reporting and modification processes by focusing on labor standards and subcontractor compliance.

Davis-Bacon Act Wage Rules

To comply with the Davis-Bacon Act, you must:

  • Use the most up-to-date prevailing wage determinations from SAM.gov for each labor category.
  • Apply the correct wage rates based on the project’s location and type of construction.
  • Keep detailed records of worker classifications and corresponding pay rates in your project files.
  • Update wage determinations if changes occur during the contract’s duration.

Payroll and Labor Documentation

Proper payroll documentation is key. Here’s what you need to do:

  • Submit certified payroll forms (WH-347) weekly to the contracting officer.
  • Include details like worker names, classifications, hours worked, and wages paid.
  • Keep payroll records for at least three years after the contract is completed.
  • Obtain signed acknowledgments from employees confirming their wage rates and benefits.

Subcontractor Rules

Managing subcontractors requires additional attention. Make sure to:

  • Include compliance clauses in all subcontractor agreements.
  • Verify that subcontractors are paying wages that meet prevailing rates.
  • Limit markup on subcontracted work to approved percentages.
  • Collect and retain monthly certified payrolls from all subcontractors.

Failing to meet these requirements can lead to audits and payment delays. Keeping thorough records is essential to stay compliant and avoid issues.

Tips to Stay Compliant

Once you’ve set up labor and reporting protocols, make compliance a part of your daily workflow. These practical steps can help you avoid violations and keep everything running smoothly.

Company Compliance Rules

  • Maintain a version-controlled digital repository to manage contract modifications, with multi-level approval processes in place.
  • Use automated reminders to stay on top of reporting deadlines.
  • Clearly document communication protocols between project managers and contracting officers to ensure consistent messaging.

Staff Compliance Training

Educate your team on GSA contract rules and their responsibilities, focusing on:

  • Key regulations like FAR Parts 8, 13, 15, and GSA Schedule policies.
  • The WH-347 certified payroll process and submitting subcontractor records.
  • Reporting timelines and critical deadlines.

Appoint a Contract Administrator and Compliance Officer to monitor training progress and ensure everyone is up to speed.

Compliance Tracking Methods

Leverage tools and systems to stay organized and on schedule:

  • Use compliance management software to monitor reporting deadlines.
  • Implement monthly checklists tailored to each active contract.
  • Keep digital logs of all contract modifications for easy access and tracking.

For comprehensive support, consider working with GSA Focus specialists who can guide you through the entire compliance process.

Tips to Stay Compliant

After setting up labor and reporting protocols, make compliance part of your daily routine. These steps can help you avoid issues and keep operations on track.

Company Compliance Rules

  • Keep a digital repository for managing contract updates, with clear version control and multi-level approval processes.
  • Set up automated reminders to never miss reporting deadlines.
  • Document communication protocols between project managers and contracting officers to ensure consistent and clear messaging.

Staff Compliance Training

Train your team on GSA contract rules and their responsibilities, emphasizing:

  • Key regulations, including FAR Parts 8, 13, 15, and GSA Schedule policies.
  • The WH-347 certified payroll process and how to handle subcontractor records.
  • Reporting schedules and critical deadlines.

Designate a Contract Administrator and Compliance Officer to oversee training and ensure everyone understands their role.

Compliance Tracking Methods

Use tools and systems to stay organized and on time:

  • Rely on compliance management software to track reporting requirements.
  • Create monthly checklists tailored to each active contract.
  • Centralize compliance tasks, deadlines, roles, and documents in a digital system with automated alerts.

This streamlined approach keeps every compliance task visible and manageable.

For additional support, consider working with GSA Focus specialists who can guide you through the compliance process.

Conclusion

By sticking to the systems and checklist provided, businesses can meet federal requirements and secure profitable GSA contracts. With nearly 44% of government awards receiving just one bid, these proactive steps can give you an edge.

Managing compliance effectively boils down to three key actions:

  • Rely on a detailed checklist to cover every contract requirement.
  • Provide regular training for your team on compliance processes.
  • Automate task and deadline tracking to stay on top of compliance efforts.

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