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Tags Archives: GSA pricing

IT-70 Prepares For a New Addition With the Creation of a Cyber Security SIN

Source: Winvale – GSA Schedule Blog

10 Important Facts About the New Health IT SIN

Source: Winvale – GSA Schedule Blog

Everything You Need to Know About the HCaTS Contract Vehicle

Source: Winvale – GSA Schedule Blog

Staying Compliant with GSA

GSA Compliant ChecklistMany GSA contractors believe that simply securing a GSA Schedule contract is the answer to quick profits. However, this could not be further from reality. Attaining a GSA Schedule is an important step, but only the first step to profitability in the government sector for commercial businesses. The government’s selection process plays a big role in the contracting process. Therefore, it becomes the responsibility of GSA contractors to properly market their products and/or services to the government and remain compliant with the requirements of the General Services Administration (GSA).

One of the main issues with selling to government agencies is remaining compliant. GSA has multiple scrutinizing compliance requirements that can easily result in hefty penalties, fines, and worst of all, a loss of business if contractors do not abide by them. These requirements are extensive and can easily be violated; As a result, many contractors have found remaining compliant to be one of the most challenging long term issues for GSA contractors.

For example, a common GSA compliance issue is simply not following the terms and conditions for the GSA Schedule program. The terms and conditions vary depending on your commercial business, and involve many topics such as minimum order threshold, delivery costs and schedule, labor qualifications, and subcontracting restrictions. These common issues are often not accurately represented and GSA contractors do not properly teach and discuss the difference to their employees.

Businesses can reduce these errors by conducting corporate wide training on GSA pricing. GSA Contractors should also distribute any self-audit proposals and invoices along with any additional materials for reference. Understanding the key differences in the terms and conditions and how they apply to your business is also crucial for your company’s success.

Due to the numerous amounts of GSA contracts and increases in competition, the GSA has recently been shrinking the number of active GSA contracts by cracking down on compliance errors. Many GSA contractors are concerned about the penalties and are trying to avoid the horror of compliance repercussions.

Although contract Terms and Conditions is one of the biggest compliance issues in GSA contracting, there are many other common compliance risks that GSA contractors must beware of. In response to the building anxiety and growing concerns, a complimentary webinar was hosted this past Halloween to address these compliance issues and provide solutions to avoiding penalization from the GSA.

You can watch the full webinar, “The Top 10 Compliance Risks for GSA Schedule Contractors” and see other past webinars on our YouTube Channel.

What is a FAR 51 Deviation?

redwhiteblue Far 51 DeviationAt first, it seems like an easy question. Who can purchase off the GSA schedule? But in practice, the answer is not always as simple. Previously, Andrew wrote a great blog describing which eligible entities can purchase off the GSA schedule.

Now that we’re clear on which eligible entities can purchase off the GSA schedule, there is just one more wrinkle to throw in. Occasionally, other contractors can be authorized by a government agency to purchase off the GSA schedule when deemed appropriate for agency requirements. This is called a FAR 51 Deviation, and it usually occurs for large-scale projects when a contractor needs to purchase other products and/or services in order to complete a “total solution” for an agency.

There are a few stipulations of the FAR 51 deviation. The supplies or services being purchased must be ancillary to the primary purpose of the contract with the federal agency, and the authorization is only available to the Federal government, not to state/local governments through cooperative purchasing. Additionally, the purchases made using the FAR 51 deviation authority can only be based on a “time and materials” or labor-hour method, not on a firm fixed price methodology. Items must also be invoiced at the price they were purchased from the contractor – i.e. the buying contractor cannot add any markup onto these items when billing the agency for them.

As a GSA contractor, if you receive an order from another contractor under a FAR 51 Deviation, there are a few things you need to do. First, be sure you have received a copy of the written authorization that is signed by the Federal agency contracting officer. You will want to keep this document for your files regarding this order, in case it comes up during your Contractor Assistance Visit. Next, you can offer the buying contractor GSA pricing (or better). If the buying contractor has their own GSA schedule, you will want to include their contract number on the purchase order or invoice. You will also want to include the following language on the invoice: “in care of ‘[name of government agency]’ under written authorization from ______ dated ______.”

Do not forget that this sale will count as a GSA sale. Be sure that you report it as such during 72A quarterly sales reporting. This means that the Industrial Funding Fee (IFF) applies to the sale, as it would to any GSA sale.

If you have any additional questions about FAR 51 Deviations, please feel free to contact Winvale!

 

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