GSA PSS/Oasis Contracts Conference on June 25, 26 2018 in Rockville, Md. GSA Contract Compliance – V5
On the Compliance side of the business, both GSA Industrial Operations Analysts (IOAs) and GSA OIG Auditors are nearly unanimous in pointing out common contractor deficiency trends. Currently out of date FSS Pricelists( they need refreshed every two years), under qualified labor ( they will want to see all your LHC resumes of billable labor to compare to your awarded schedule LHC qualifications) and overcharging Fed agencies when they were entitled to a Prompt Payment Discount or Volume Discount are the most common things they find. It was also repeatedly stated that if you find something wrong while working on your contract or prepping for an inspection, you have 15 days to disclose the matter to your GSA Contracting Officer to be on the safe side. They continue to emphasize the importance of having an effective Sales Tracking System so that the proper Sales are reported and IFF paid. IFF supports GSA FAS and not the taxpayer, so they are very sensitive on this topic. If you get notified that you are scheduled for a Contractor Assessment Visit ( CAV) whether face to face or virtual or a GSA OIG Audit ( these folks don’t play around) then give us a call. We can both prepare you for the CAV or audit and also sit in on the review with you.
MASS MODS are or have recently been issued concerning the Commercial Sale Agreement (CSA) and OLMs or Order Level materials, which are frankly ODCs purchased at the order level. Like many things with GSA you don’t get one without the other, so you need to accept the CSA Mass mod to get the OLM carrot. You need the OLM capability to be competitive at all or you will sitting on the sidelines watching contracts and task orders go elsewhere. Currently there are seven GSA schedules authorized to use OLMs. They are schedules 03FAC, 56, 70, 71, 84, OOCORP and 738X. There also is a move afoot to begin consolidating SINs particularly in the Products Schedules area. The Services side of the schedules house consolidated in 2015 as OOCORP (PSS) and the General Products side has yet to be done. A future newsletter will provide more info on that topic as available.
Good Luck in the 4th Qtr and call us at 914-693-0728 on the East Coast or 410-375-7886 in the Midwest or West Coast if you need some assistance in prepping Emods or RFQs/RFPS or Compliance matters. We have branches in Virginia Beach, VA and in the Chicago area. You can also get us at firstname.lastname@example.org. (Email)