If you hold a GSA Schedule Contract, compliance is non-negotiable. Failing to meet requirements can lead to contract termination, fines, or even legal investigations. Here’s a quick breakdown of the key areas you must focus on to maintain compliance:

• Sales Reporting: Submit accurate sales data quarterly and pay the 0.75% Industrial Funding Fee (IFF) on time.
• Minimum Sales: Generate at least $25,000 in sales within the first two years and maintain this annually.
• SAM Registration: Keep your SAM.gov profile updated, including ownership, banking, and business details.
• Trade Agreements Act (TAA): Ensure products are from TAA-compliant countries and maintain proper supply chain documentation.
• Contract Updates: Regularly update pricing, product listings, and company information on GSA platforms like eMod and GSA Advantage!.

Why It Matters

• Contracts not meeting stricter 2025 compliance standards will expire.
• Non-compliance risks include fines, suspension, and False Claims Act investigations.

Pro Tip: Set reminders for key deadlines and consider professional compliance support to simplify processes like SAM registration, sales tracking, and documentation management.

For small businesses, compliance is especially critical since only 4% currently hold GSA Schedules. Staying compliant secures access to a $70 billion federal marketplace.

Keeping your GSA Multiple Award Schedule (MAS) Contract Compliant

SAM Registration Requirements

Having an active registration on SAM.gov is essential for maintaining GSA Schedule compliance. Since April 2022, SAM.gov has transitioned to using the Unique Entity ID (UEI) system, replacing the older DUNS Number process. Without an up-to-date SAM registration, contractors cannot receive federal payments or accept new task orders.

Basic SAM Registration Steps

To register on SAM.gov, you’ll need specific credentials and documentation:

Here’s how to complete the registration process:

• Create a Login.gov Account: Approval for your account may take up to 14 business days.
• Complete Core Data Entry: Enter your business details exactly as they appear on IRS records to avoid validation delays.
• Submit Certifications: Accurately certify your business size, status, and compliance with regulations to avoid penalties.

Yearly SAM Updates

SAM.gov issues renewal reminders at 60, 30, and 15 days before your registration expires. However, you must also update your SAM profile immediately if there are changes to:

• Ownership
• Legal name
• Address
• Banking details
• Business size

Failing to renew or update your registration could result in non-compliance, delayed payments, suspended orders, or even contract termination.

Pro Tip: Set internal reminders 45 days before your SAM registration expires and assign a specific team member to handle renewals. This extra time can help you resolve any validation issues well before the deadline.

Finally, ensure your SAM banking details match your current EFT information. This is crucial for receiving payments and remitting IFF. Keeping your SAM data accurate not only ensures federal agencies can authorize your orders but also supports reliable sales reporting and overall contract compliance.

Sales Reports and Revenue Goals

Keeping your GSA Schedule active isn’t just about timely SAM updates – it also depends on accurate and timely sales reporting. Sales reports play a crucial role in maintaining your market access and contract compliance.

TDR and IFF Reporting

The reporting schedule depends on your contract type. Here’s a quick look at the deadlines for both non-TDR and TDR contracts:

For contractors under Transactional Data Reporting (TDR), monthly reports are required by the 30th of each month. These reports should include key details like product descriptions, part numbers, quantities, unit prices, and the total transaction value.

Additionally, the Industrial Funding Fee (IFF) – set at 0.75% of your total GSA sales – must be submitted alongside each sales report. Even if you have zero sales for a reporting period, you’re still required to file a report indicating no activity.

Minimum Sales Requirements

GSA Schedule contractors are expected to generate at least $25,000 in sales within the first two years of their contract and maintain this level annually thereafter.

Under the "Rightsize the Multiple Award Schedule Program", contracts that fail to meet these sales thresholds may be at risk of expiration or cancellation. To stay on track, consider these practices:

• Use a reliable sales tracking system.
• Set automated reminders for reporting deadlines.
• Assign a team member to oversee GSA sales monitoring.
• Keep thorough records of all GSA transactions.
• Explore professional compliance support if needed.

Pro Tip: A sales tracking dashboard can help you spot and address potential shortfalls well before deadlines hit.

If you’re falling short of the sales requirements, GSA typically sends a notification and provides an opportunity to resolve the issue before taking further action.

Trade Agreements Act Rules

The Trade Agreements Act (TAA) requires that products sold under government contracts be either manufactured or substantially transformed in the U.S. or a TAA-approved country. Following these rules is critical to keeping your contract in good standing and avoiding hefty penalties. Below, we’ll cover the key aspects of TAA compliance and the documentation you need to stay on track.

Approved TAA Countries

To meet TAA requirements, products listed on GSA Schedules must come from specific approved countries. Here’s a breakdown of compliance by region:

A product qualifies as TAA-compliant if it is fully manufactured or substantially transformed in a TAA-designated country. Substantial transformation refers to significant changes that alter the product’s form, function, or character. However, verifying the country of origin is only one piece of the puzzle – thorough supply chain documentation is equally important.

Supply Chain Documentation

To ensure compliance, maintaining detailed records of your supply chain is non-negotiable. Here’s what you need to focus on:

• Primary Documentation
  Collect and organize essential records such as certificates of origin, manufacturing logs, and supplier attestations. These documents prove the product’s compliance with TAA rules.
• Supply Chain Tracking
  Use tracking systems to monitor where components are sourced, where manufacturing takes place, and how the product is assembled. This level of detail is crucial for verifying compliance.
• Audit Preparation
  Be ready for potential GSA audits by keeping your documentation well-organized and easily accessible. Digital systems can make this process more efficient and reduce risks of oversight.

Important: If you identify non-compliant products, act immediately. Remove them from your offerings, notify your GSA contracting officer, document the steps you take to address the issue, and review your supply chain to prevent future risks.

With stricter enforcement of TAA rules anticipated in 2025, staying proactive is more important than ever. Regular internal audits and a thorough review of your supply chain documentation can help you avoid compliance issues and maintain contract stability.

For businesses dealing with complex supply chains or uncertain compliance requirements, professional services can provide expert guidance. These services can help you manage documentation and reduce the risk of non-compliance.

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Contract and Price Updates

Keeping contracts and pricing accurate on GSA platforms is essential for maintaining compliance and staying competitive.

GSA Platform Updates

To ensure your GSA contract information is always up-to-date, you need to monitor and update details across multiple platforms regularly. The GSA eMod system is your go-to tool for submitting contract modifications. Once approved, these updates appear on both GSA eLibrary and GSA Advantage!.

Here’s a quick breakdown of the key areas to focus on:

Important Update Guidelines:

• Submit eMod modifications within 30 days of any commercial changes.
• Keep negotiator contact details current.
• Always include supporting documentation for every change.

After submitting updates, double-check that the changes are reflected on both GSA eLibrary and GSA Advantage!. Additionally, pricing strategies must align with compliance rules to uphold the integrity of your contract.

Most Favored Customer Pricing

The Most Favored Customer (MFC) rule is a cornerstone of GSA pricing compliance. It ensures that the government receives pricing that is as good as – or better than – your best commercial deals.

How to Stay Compliant with MFC:

• Regularly review your commercial pricing to confirm government rates remain competitive.
• Keep thorough documentation comparing commercial and government pricing.
• Maintain detailed records of your commercial sales practices.
• Update GSA pricing promptly when your commercial rates change.

What You’ll Need for Price Changes:

• Updated commercial price lists.
• Evidence of commercial sales at the new prices.
• Market analysis that justifies the changes.
• A comparison of the new rates with existing government prices.

Failing to comply with pricing rules can have serious consequences. For instance, GSA has started letting MAS contracts expire if they fail to meet minimum sales thresholds, as outlined in FSS Clause I-FSS-639. Performing regular internal audits of your pricing structure can help you avoid these pitfalls and maintain compliance.

If your updates involve complex changes across multiple product lines, consider seeking professional compliance assistance to simplify the process.

Professional Compliance Support

Navigating GSA Schedule compliance can be challenging, but professional assistance simplifies the process and ensures you meet strict regulatory requirements.

GSA Focus Services

GSA Focus offers tailored solutions to help contractors maintain their GSA Schedule status. Their services target critical areas of compliance with a structured approach:

These services integrate smoothly with other compliance processes, supporting your GSA standing. They complement SAM registration and sales reporting requirements, ensuring all bases are covered.

Professional support is invaluable for managing complex reporting tasks. GSA Focus employs advanced monitoring systems to:

• Track performance against GSA scorecard objectives
• Keep audit-ready documentation organized
• Ensure timely submission of all required reports
• Monitor sales thresholds to prevent contract termination

For contractors facing specific challenges, expert guidance is available throughout the reporting cycles. VA Schedule reporting deadlines are also seamlessly incorporated into the compliance calendar.

Streamlined Compliance Management

Professional compliance services leverage technology to simplify contract management. Tools like automated tracking systems and secure document repositories help contractors avoid common pitfalls and maintain compliance.

With GSA increasing its focus on compliance, professional support not only reduces risks but also enhances your overall performance. Key benefits include:

• Internal audits to proactively identify and resolve issues
• Quick responses to GSA inquiries
• Expert assistance during official reviews

Investing in professional compliance support often pays off by preventing the costly consequences of non-compliance, such as contract termination or losing federal business opportunities.

Summary

Staying compliant with GSA Schedule requirements involves sticking to several key rules. These include maintaining an active SAM registration, submitting sales and IFF reports on time, meeting minimum sales requirements, and adhering to Trade Agreements Act regulations.

To keep their contract in good standing, contractors must generate at least $25,000 in GSA sales within the first two years and sustain that level annually thereafter. This aligns with GSA’s effort to "Rightsize the Multiple Awards Schedule Program", ensuring that only active, productive contracts remain in the program.

Each compliance area has its own reporting schedule, so it’s important to regularly review cycles related to SAM, sales, and pricing. Staying on top of these cycles is critical to maintaining your contract status and avoiding potential violations.

For businesses looking to simplify this process, professional compliance management services like those offered by GSA Focus can make a big difference. Their structured methods have helped clients stay compliant while focusing on their core operations, with an impressive 87x average ROI and a 98% success rate in maintaining compliant GSA contracts.

This support is especially important for small businesses, as only 4% of them currently hold GSA Schedules. A strong compliance program is essential for tapping into federal contracting opportunities.

Ultimately, these measures are vital to protecting your success in federal contracting. Non-compliance can lead to severe consequences, including contract termination, financial penalties, and the loss of valuable federal business opportunities. Whether handled internally or with the help of experts like GSA Focus, effective compliance management is the foundation of long-term success in federal contracting.

FAQs

How can I ensure my products comply with the Trade Agreements Act (TAA) and avoid potential penalties?

To make sure your products meet Trade Agreements Act (TAA) requirements and avoid any penalties, start by confirming that they are either manufactured or substantially transformed in a TAA-approved country. The U.S. government provides a list of these countries, which includes nations with established trade agreements with the U.S.

It’s also crucial to keep thorough documentation and records for all your products. This will help prove compliance if you’re ever audited. Regularly check your supply chain to ensure no changes have affected your product’s compliance status. If you’re uncertain about meeting TAA standards, consulting with a professional can make the process easier and help minimize compliance risks.

What steps can small businesses take to maintain their GSA Schedule and succeed in the federal marketplace?

Small businesses have a better shot at keeping their GSA Schedule and succeeding in the federal marketplace when they consistently meet compliance standards and stay on top of their contract responsibilities. Working with GSA Focus can make this process much easier. They provide a range of services, including help with document preparation, ensuring compliance, and offering guidance during negotiations.

By taking the guesswork out of managing a GSA Schedule, small businesses can shift their energy toward using these contracts to tap into profitable federal contracting opportunities and expand their operations.

What happens if I don’t meet the minimum sales requirements for my GSA Schedule contract, and how can I avoid or address this issue?

Failing to meet the minimum sales requirements for your GSA Schedule contract – usually $25,000 in sales within the first two years and every year after – can result in your contract being canceled. This rule ensures that GSA contracts stay active and worthwhile for both you and the government.

To avoid falling behind, focus on actively marketing your products or services to federal agencies. Keep your GSA Advantage catalog up to date, and make the most of the unique benefits your contract offers. If you’re already struggling to meet the sales threshold, it might be time to consult a GSA expert who can help you develop strategies to improve your sales and stay compliant. Staying proactive and informed is essential for maintaining your GSA Schedule and achieving long-term success.

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