GSA Schedule Audits
Prevent a GSA Schedule Audit
Now that you’ve invested considerable time and resources to establish GSA Schedule, it’s important to remember to keep it in compliance since your company can, at any time, be subject to a GSA Schedule audit. As an approved GSA contractor, you join GSA in servicing federal customers and will be tasked with recognizing and quickly adapting to changes in federal regulations.
The major responsibilities to keep in mind for maintaining your Schedule is that your GSA pricelist is kept up-to-date, that you monitor and disclose changes to your commercial sales practices, and that you are fulfilling your reporting requirements.
An effective corporate compliance program will entail aligning business functions/personnel with your new contract responsibilities.
Sales and Accounting
- Reporting GSA Sales: A critical element in the success of your relationship with GSA, reporting your sales ensures the Industrial Funding Fee (IFF) is remitted to GSA on a quarterly basis. The IFF is a fee paid by customers to cover GSA’s cost of operating the Federal Supply Schedules program. This fee is a percentage of reported sales under Schedules contracts.
- Small Business Subcontracting: Including Individual and Commercial Plans, SBA Goals, Supplier Identification, Good Faith Effort Definition, and eSRS.gov Reporting.
- Sales Tracking System to Monitor Basis of Award (BOA) Pricing
- Corporate Accounting: Including Direct and Indirect Cost Identification, Approved Costing Practices (modified CAS – 401, 402, 405, and 406), Government and WAWF Invoicing, and Prompt Payment Act.
Operations and Administration
- CCR & ORCA
- Code of Business Ethics and Conduct Policies
- Corporate Compliance: Including FAR and GSAR interpretations, IOA visits, OIG Audits, False Claim Act (31 U.S.C. §3729-3733) and Qui Tam.
- Affirmative Action
- EEO-1 & EEOC
- Davis-Bacon Wage Determinations
- Service Contract Act
- Labor Category Qualifications
The MAS program is the premier government acquisition program that mirrors commercial buying practices. Prior to contract award, GSA will analyze an offeror’s commercial sales practices to determine who is the Most Favored Customer (MFC) for the offered products or services. This becomes the “Basis of Award customer” around which contract pricing is negotiated with the federal government establishing a discount relationship between your MFC pricing and the pricing offered to GSA.
According to GSA’s price reductions clause, this discount delta relationship shall be maintained throughout the contract period. Changes in the discount to the MFC require an equal change to GSA’s discount. This is one of the most important compliance factors to keep in mind when establishing and maintaining a GSA Schedule. As such, it is critical that contractors establish a system or process to monitor this relationship throughout the life of their contract.