Designate a single person in your financial organization as the GSA Compliance Officer. Whether full or part time, the person must have the authority to ensure GSA contract compliance and be accountable for making the company compliant. In order of importance, the responsibilities of the GSA Compliance Officer should be:
- To document and enforce the discounting policies used to establish the GSA Basis of Award pricing structure.
- To design and enforce compliance procedures that outline the consequences for discounting violations committed by the sales staff. For example, monetary penalties could be imposed for one-time violators; repeat offenders might face termination. Obtain CEO approval of the compliance policies and procedures.
- To train sales staff and management in all aspects of GSA compliance.
- To monitor Basis of Award customer quotes and orders for compliance.
- To ensure the accuracy and payment of the quarterly Industrial Funding Fee to GSA on time. (GSA will love you for this one.)
- To monitor Trade Agreement Act compliance.
- To review each GSA order for excessive or unmarked open market items and out-of-scope work or products.
Most importantly, your company's GSA compliance officer should establish an open and ongoing relationship with the GSA contracting officer. Contract problems and proposed solutions should be communicated in writing and by telephone as soon as they are discovered. The two parties should establish a relationship based on trust and a commonly held view that your company and the government are partners.
This is the real secret of contract compliance. Experienced federal contractors know this, which is one of the reasons they get bigger and bigger.
