GSA Compliance: Don’t Get Lost

GSA Compliance is as important as ever, and it is easy to get lost in the complicated Terms And Conditions of a GSA Contract.

With the GSA sending out cancellation letters like never before, there is actually great risk in missing GSA Contract compliance marks. Anything other than “Excellent” on your Contractor Report Card puts your company at risk of losing your GSA Contract and the revenue that it generates.

To that end, I have created a short list of questions you must answer to keep GSA compliance. This does not cover everything, but in my experience, these are the hot areas where many GSA Contractors fail.

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Are you meeting the $25,000 sales requirement?

You must sale at least $25,000 through your GSA Contract in the first two years after award, and then every year after that. Many GSA Contractors are failing this test and most will lose their GSA Contract as a result. Developing and keeping to a solid Federal Marketing Plan is the only way to go. You can’t just sit back and wait for sales to come to you.

Have you been reporting your Quarterly GSA Sales and paying the IFF fee? 

The GSA is mostly funded through these IFF payments, so you can bet they care if you report and pay or not. Even if you didn’t have any GSA sales this quarter, you must report zero sales.

Is your GSA Advantage and/or Text File up-to date? 

As your GSA Contract is updated, you must keep updating your Text File and GSA Advantage. This requires some work, but it is important in order to keep your GSA Contract Compliant.

Are your GSA purchases at the negotiated prices or below? 

You went through negotiations with the GSA, and they will ask you for PO’s and invoices to make sure you are charging the negotiated prices or below. This is lightly audited in the CAV visits, and you may have to cut checks back to the buyer if you overcharged them.

Are your Commercial Sales (for your Basis of Award) at the disclosed prices or above? 

You told the GSA that you would give them a general discount from a customer type (called your Basis of Award or BOA), and if you have been discounting your prices on BOA sales, then your GSA prices have automatically dropped too. It is called triggering the Price Reductions Clause, and it can cause some real GSA Compliance problems.

Are you only selling items through GSA that are NOT on your GSA Contract? 

You would be surprised how many GSA Contractors get caught selling items that are not on contract. If it wasn’t added originally, and wasn’t added through the modification process, then you cannot sale it through GSA. And, if the item is made in China, then you could get in big GSA Compliance trouble.

Are any products on your contract not compliant with the Trade Agreement Act?

One of the documents you sign in getting your GSA Contract promises them that all of your products (and services) are not made in China, India, Thailand, or any other countries not on the “good list.”

For GSA Sales, is your GSA Contract Number cited? Likewise, is your GSA Number absent from federal purchases that are not through GSA? 

On Invoices, PO’s, Proposals, etc. you must cite your GSA Number if the sale is through your GSA Contract, and any items not on your GSA Contract must be labeled accordingly as well. Likewise, if your proposal does not include any GSA items, then you should not list your GSA number anywhere.

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There are certainly more areas where you must keep GSA compliance, these are just very common ones. So, this list is not complete, and don’t call me yelling if you are not compliant and you followed my list. However, this is a really good start if you do not have any clue on how to be GSA Contract Compliant. I would also advise you to grow and learn in this topic, and communicate with your GSA Contracting Specialist or a GSA Consultant when preparing your internal processes for tracking GSA Sales, and preparing for general  GSA compliance.

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