Pre-Award GSA OIG Audits
A pre-award GSA OIG audit is an audit of a contractor’s Commercial Sales Practices (CSP) to determine possible defective pricing. Performed by GSA’s Office of Inspector General (OIG), a pre-award GSA OIG audit focuses on what the government should have been told during GSA contract negotiations based on a full and accurate disclosure of commercial sales data. Most GSA contractors seem to have challenges submitting accurate CSP data and the latest round of pre-award GSA OIG audits seem to demonstrate this. Focused on 53 GSA Schedule contractors, the OIG’s report on “Major Issues from GSA MAS pre-award audits” reported:
• 29 contractors (69%) submitted noncurrent, inaccurate, and/or incomplete CSP information;
• 7 contractors (13%) had no commercial sales;
• 18 contractors (34%) did not have adequate systems for accumulating and reporting GSA Schedule sales;
• 19 contractors (36%) did not properly compute the IFF;
• 7 out of 21 service contractors (33%) charged agencies for labor that did not meet the qualifications required by their contracts.
Submitting inaccurate CSP data can have significant consequences for GSA contractors, including penalties, fines, suspension, and debarment. Don’t wait until the OIG picks you next for a pre-award GSA OIG audit. Be proactive, and make sure you’re staying up to date with all potential fees and penalties and be sure to contact the professionals for any further consulting in this matter.