1. Federal Acquisition Service U.S. General Services Administration Keeping Your GSA Schedule Contract Compliant Laura E. Smith Industrial Operations Analyst Office of Supplier Management May 27, 2015

2. Federal Acquisition Service Contents GSA Personnel Contract Compliance Sales Reporting and Industrial Funding Fee Remittance Basis of Award Pricing Prompt Payment Discounts Scope of Contract Compliance Trade Agreements Act (TAA) Other Administrative & Compliance Concerns Contract Assessments

3. Federal Acquisition Service GSA Personnel Procurement Contracting Officer (PCO) Awards your contract Approves bilateral modifications PCO contact information can be found on GSA eLibrary: http://gsaelibrary.gsa.gov http://gsaelibrary.gsa.gov Ultimate authority over your GSA Schedule contract Administrative Contracting Officer (ACO) Delegated functions by the PCO ACO contact information can be found at https://vsc.gsa.gov/vsc/aco_ioa.cfm https://vsc.gsa.gov/vsc/aco_ioa.cfm

4. Federal Acquisition Service GSA Personnel (Cont.) Industrial Operations Analyst (IOA) Conducts contractor assessments Monitors sales reporting, sales adjustments, and Industrial Funding Fee remittance Provides general guidance and business development support IOA contact information can be found at https://vsc.gsa.gov/vsc/aco_ioa.cfm https://vsc.gsa.gov/vsc/aco_ioa.cfm

5. Federal Acquisition Service Changes to the ACO and IOA Roles ACO Previously responsible for monitoring sales reports, IFF payments and processing sales adjustment Previously responsible for updates to Contractor Records Location Still responsible for updates to contract 72a and Administrative Representatives Still responsible for administering mass mods, monitoring subcontracting plan reports, and contract closeouts IOA Now responsible for monitoring sales reports, IFF payments, and processing sales adjustments Now responsible for updates to Contractor Records Locations (SIOA) Still responsible for conducting Contract Assessments (formerly CAVs)

6. Federal Acquisition Service Modification Types Contractor Initiated Pricelist Company Information Legal GSA Initiated Mass Mods

7. Federal Acquisition Service Mass Modification GSA Initiated Modification to all Schedule Contractors Emailed to Contract Administrator by the ACO Completed at GSA’s Mass Modification WebsiteMass Modification Website

8. Federal Acquisition Service Sales Reporting and Industrial Funding Fee (IFF) Remittance Previous ACO responsibility, now monitored by the IOA Sales reports must be submitted and IFF remitted within 30 days after the end of the quarter, by: January 30 th, April 30 th, July 30 th, and October 30 th $0 must be reported if you have no sales for the quarter Do not report open market items and travel costs Some GSA BPAs have additional sales reporting requirements

9. Federal Acquisition Service Sales Tracking System Identifies, tracks, and reports GSA sales accurately and completely Reports all transactions within the proper period Retrieves data easily Separates Schedule sales from other federal sales and commercial sales Report sales by: Order date Shipment date Invoice date Payment date

10. Federal Acquisition Service Indicators of a Schedule Sale The GSA contract number is stated If no contract vehicle is stated and: Same terms and conditions as your GSA contract Through GSA Advantage!® or eBuy Paid with the government purchase card for items on your contract The pricing at or below contract price

11. Federal Acquisition Service Basis of Award Discount relationship upon which your GSA pricing is predicated Usually found on the Standard Form 1449, Final Proposal Revision, or subsequent modifications (Standard Form 30) Must be maintained to comply with Price Reductions Clause (GSAM 552.238-75) Adverse changes are referred to as “price reductions” Price reductions should be reported to the PCO within 15 calendar days

12. Federal Acquisition Service Pricing Must charge at or below your GSA Schedule price Price increases (Economic Price Adjustments) must be approved by your PCO Automatic escalations One-time increases Refer to clauses 552.216-70 (based on a commercial price list) and I-FSS-969 (pricing based on other than a commercial price list) Contractors may be required to repay overcharges on Schedule orders

13. Federal Acquisition Service Prompt Payment Discounts Awarded prompt payment discount terms must be displayed on all MAS invoices and applied correctly to MAS orders Do not apply to government purchase card payments Terms should be included in all MAS quotations Prompt Payment Discounts not applied correctly may constitute overcharges

14. Federal Acquisition Service Scope of Contract Compliance Contract items must be within the scope of the Schedule and approved Special Item Numbers (SINs) Only items awarded on your GSA Schedule pricelist can be sold per your contract “Open Market” (non-contract) items must be clearly identified Expand the scope of your offerings through: Modifications Additional GSA Schedule contracts Contractor Teaming Arrangements (CTAs)

15. Federal Acquisition Service Trade Agreements Act (TAA) Must ensure offerings are manufactured in a TAA compliant country Applicable to all Schedule contracts (including services) TAA compliant countries can be found under FAR 25.003 Review your pricelist and GSA Advantage!® file for accuracy and possible noncompliant items Notify your PCO if noncompliance is uncovered

16. Federal Acquisition Service Other Compliance Concerns Labor qualifications Environmental icons Subcontracting plans Delivery GSA Advantage Pricelist

17. Federal Acquisition Service Contractor Assessments Objectives Assess the level of compliance with GSA Schedule terms & conditions Address questions or concerns Evaluate processes and procedures Performed for most GSA Schedules

18. Federal Acquisition Service Assessment Frequency Annually for contractors that meet established MAS reported sales thresholds Focus on sales tracking, pricing, and prompt payment discounts End-of-term for contractors in the 4 th contract year meeting established MAS reported sales thresholds Covers all compliance topics in this presentation

19. Federal Acquisition Service Assessment Preparation Initial phone call or email from IOA, followed by pre- visit confirmation email Familiarize yourself with the requirements addressed in pre-visit emails Contact IOA with any questions

20. Federal Acquisition Service Virtual Assessments Mutually agreed upon by IOA and contractor Conducted over the Internet, web conferencing, email, and/or telephone Topics and documents required are the same as in- person meetings Benefits include potential cost savings to Government and contractor

21. Federal Acquisition Service CAV Intent Notice Provided by your IOA prior to the Assessment Purpose is to eliminate any confusion between Assessments and IG Audits Should be reviewed, signed, and given back to your IOA

22. Federal Acquisition Service Recommended Documentation GSA contract, including: Standard Form 1449 (SF 1449) Incorporated documents (e.g. Final Proposal Revision (FPR) letter, Commercial Sales Practices) Approved modifications (Standard Form 30) Current approved pricelist and all previously approved versions

23. Federal Acquisition Service Recommended Documentation (Cont.) Sales data supporting your reported 72A sales for the quarters being reviewed IOAs have access to the reported sales figures but not the supporting records Examples of supporting records for reported sales: Accounting reports Spreadsheets Ledgers Invoices

24. Federal Acquisition Service Recommended Documentation (Cont.) Purchase/Task Orders Customers do not provide GSA copies of orders they place against GSA Schedule contracts As applicable: Statement of Work (SOW) Quotations Invoices Shipping information for GSA orders

25. Federal Acquisition Service Recommended Documentation (Cont.) Trade Agreements Act (TAA) Contractors supplying tangible products should be able to provide country of origin information Environmental Attributes Documentation supporting the use of environmental icons on GSA Advantage!® (excluding Energy Star and EPEAT)

26. Federal Acquisition Service Questions ? Laura E. Smith Industrial Operations Analyst GSA, Federal Acquisition Service Office of Supplier Management (817) 422-1423 Laura.E.Smith@gsa.gov