GSA Compliance System

What Is At Stake

A GSA compliance regimen is a requirement for any organization that is awarded a GSA Schedule contract. A GSA Schedule contract stipulates the pricing offered to the government as well as a series of restrictions on the pricing that may be offered to customers other than those buying under the GSA Schedule contract. In addition, a multitude of reporting and governance requirements are set that dictate the posture and profile the organization must maintain in order to remain in compliance with the terms of the awarded GSA contract.

Any time a sale is made, the pricing extended for that sale needs to be verified against the restrictions placed on pricing under the terms of the GSA contract. This is true for both sales that are affected under the GSA contract as well as sales to customers other than GSA customers. In other words, there is a direct connection between pricing extended on any sale and the risk of falling afoul of pricing restrictions imposed by the contract. The organizations that are unable to effectively implement a regimen that actively assures the adherence of its pricing to GSA contract requirements run the risk of jeopardizing the integrity of their GSA contract. Penalties, claw backs, and, at worse, contract cancellation are potential repercussions of such lapses.

Additionally, throughout the lifetime of the contract, an organization must maintain the profile and posture required to fulfill its obligations against a set of administrative and reporting requirements that will determine continued compliance in this area for the organization. The requirements span all the way from assuring regular reporting of sales activity under the GSA contract, to maintaining active registrations within a multitude of government systems, through the continued adherence to best-effort duties under subcontracting commitments.

It is imperative for any organization that is serious about maintaining the integrity of its GSA contract to implement a compliance regimen that assures its continued adherence to the terms and conditions of its GSA contract. Along with the GSA contract award, comes the potential for an audit to verify the organization's ability to meet the terms and conditions of its GSA contract.

Objectives of a GSA Compliance System Implementation

1. Designate clear lines of authority and accountability for compliance
2. Disclose discounting practices completely and accurately in the initial GSA schedule proposal,
3. Or, if the system is implemented during a contract period, correct any discounting inaccuracies immediately and inform GSA of the inaccuracies
4. Appoint a senior person as the GSA Compliance Officer
5. Communicate any possible compliance violation issues in writing to the GSA contracting officer immediately upon detection
6. Propose swift and practical corrective actions and requests guidance and approval of your actions from the contracting officer
7. Establish proper data handling for reporting purposes
8. Structure accounting procedures for GSA Schedule sales recording
   
9. Establish a calendar of compliance activities
   

GSA Compliance System Procedures

The GSA Compliance System is stood up in collaboration with Fedmarket GSA specialists. These specialists assist your organization in implementing specific policies, procedures, and systems for the following compliance functions.

1. GSA Order Segregation
2. Price Reduction Clause Compliance
3. Sales Staff Directives and Training
4. Tracking and Reporting GSA Sales
5. Trade Agreement Act (TAA) Compliance
6. Compliance with Federal Wage and Benefit Laws
7. Compliance with Time and Material Task Orders
8. Business Size Standard Compliance
9. Compliance with Reporting Requirements
10. Contract Administration
11. Uploading Price Files to GSA Advantage
12. Price Adjustments
13. Invoicing
14. Meeting Minimum Sales Requirements
15. Reporting Requirements
    • Vets 100
    • EEO-1
    • Subcontracting Plan Reporting
    • Administrative Reporting
16. American Recovery and Reinvestment Act (ARRA aka Stimulus) Reporting
17. Keeping Central Contractor Registration (CCR) Current
18. Keeping Online Representations and Certifications Application (ORCA) Current
19. Small Business Subcontracting Plan Administration
20. Miscellaneous Compliance Requirements

Implementation Methodology

The GSA Compliance System includes procedures to ensure that all aspects of GSA Schedule contract compliance are performed effectively. Upon System implementation, your organization is prepared for a GSA compliance audit at any time and your risk of dollar claw backs due to discounting violations will be mitigated.