Preparing for a MAS Contract Assessment

Carrie L. Cuevas

Master Industrial Operations Analyst

General Services Administration

May 10, 2016

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Contents

GSA Personnel

Contract Assessments

Contract Assessment Compliance Topics

Sales Reporting and Industrial Funding Fee Remittance

Pricing

Prompt Payment Discounts

Scope of Contract

Trade Agreements Act (TAA)

Basis of Award

Additional Compliance Concerns

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GSA Personnel

Procurement Contracting Officer (PCO) Awards your contract

Approves bilateral modifications

PCO contact information can be found on GSA eLibrary: http://gsaelibrary.gsa.gov

Ultimate authority over your GSA Schedule contract

Administrative Contracting Officer (ACO) Delegated functions by the PCO

ACO contact information can be found at https://vsc.gsa.gov/tools/aco_ioa.cfm

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GSA Personnel (Cont.)

Industrial Operations Analyst (IOA)

Conducts contractor assessments

Monitors sales reporting, sales

adjustments, and Industrial Funding Fee remittance

Provides general contract compliance

guidance

IOA contact information can be found

at https://vsc.gsa.gov/tools/aco_ioa.cfm

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Contractor Assessments

Objectives • Performed for most GSA Schedules

• Assess the level of compliance with GSA Schedule terms & conditions

• Evaluate processes and procedures through a review of past transactions

• Address contractor questions or concerns

Output Copy of the report emailed simultaneously to the

contractor, PCO and ACO

Not distributed externally

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Assessment Frequency

Annually for contractors meeting established MAS reported sales thresholds

• Focus on sales tracking, pricing, and prompt payment discounts

End of term for contractors in the 4th contract year meeting established MAS reported sales thresholds

• Covers all compliance topics in this presentation

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Assessment Participants

Your Company

GSA Contract Administrator

Other relevant personnel

responsible for contractual

functions (e.g. sales, basis of

award, order tracking, IFF

remittance)

GSA

Industrial Operations Analyst (IOA)

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Assessment Preparation

Initial phone call or email from IOA, followed by

a pre-visit confirmation email detailing

requirements

Familiarize yourself with the requirements

addressed in the pre-visit email

Contact IOA with any questions

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Virtual Assessments

Mutually agreed upon by the IOA and contractor

Conducted over the Internet, web conferencing,

email, and/or telephone

Topics and documents required are the same as in-

person meetings

Benefits include potential cost and time savings to

the Government and contractor

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Recommended Documentation

GSA contract, including:

• Standard Form 1449 (SF 1449)

• Incorporated documents (e.g. Final Proposal

Revision (FPR) letter, Commercial Sales Practices)

Approved modifications (Standard Form

30) and referenced attachments

Current approved pricelist and all

previously approved versions

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Recommended Documentation

(Cont.)

Sales data supporting your reported 72A sales for

the quarters being reviewed

• IOAs request all sales data including both MAS and non-

MAS for the sample time period

Examples of supporting records for reported sales: • Accounting reports

• Spreadsheets

• Ledgers

• Invoices

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Recommended Documentation

(Cont.) Purchase/Task Orders

• Customers do not provide GSA copies of orders they

place against GSA Schedule contracts

Related Documentation:

• Request for Quote (RFQ)

• Statement of Work (SOW)

• Quotations

• Invoices

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Recommended Documentation

(Cont.)

Trade Agreements Act (TAA)

• Contractors supplying tangible products should be

able to provide country of origin information

Environmental Attributes

• Documentation supporting the use of

environmental icons on GSA Advantage!®

(excluding Energy Star and EPEAT)

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Contract Compliance Overview

GSA and Ordering Agencies:

Abide by the Federal Acquisition Regulation (FAR) and

agency regulations

Ordering agencies must abide by the MAS terms and

conditions

GSA PCO has ultimate authority over the MAS contract

Contractors:

Must be in compliance with MAS contract terms and

conditions and purchase/task order terms and conditions

Your GSA customer cannot negotiate less favorable

terms

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Sales Tracking System

Identifies, tracks and reports GSA sales

accurately, completely, and timely

Reports all transactions within the proper period

Separates Schedule sales from other federal

sales and commercial sales

Retrieves data easily

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Indicators of a Schedule Sale

GSA contract number is stated on a order from an

eligible user (see GSA Order ADM 4800.2H)

Sale to private company with a Letter of

Authorization using FAR 51 or a FAR 51 Deviation

Contractor teaming arrangement or authorized

dealer approved on Schedule contract

If no contract vehicle is stated and:

Same terms and conditions as your GSA contract

Through GSA Advantage!® or eBuy

Paid with the government purchase card for items on your

contract

The pricing at or below contract price

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Sales Reporting and Industrial Funding

Fee (IFF) Remittance

Sales reports must be submitted and IFF remitted

within 30 days after the end of the quarter, by:

January 30th, April 30th, July 30th, and October 30th

$0 must be reported if you have no sales for the

quarter

Do not report open market items and travel costs

The IFF of 0.75% is included in your awarded pricing

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Pricing

Must charge at or below your GSA Schedule

price

Price increases (Economic Price Adjustments)

must be approved by your GSA PCO

Automatic escalations

• Incorporated into the original contract (SF 1449) or

subsequent modifications (SF 30)

One-time increases

• Incorporated through a modification (SF 30)

Refer to clauses 552.216-70 and I-FSS-969

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Prompt Payment Discounts

Awarded prompt payment discount terms must be

displayed on all MAS invoices

Terms can be communicated on all MAS

quotations

Do not apply to government purchase card

payments

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Scope of Contract and SINs

Contract items must be within the scope of the

Schedule and approved Special Item Numbers

(SINs)

“Open Market” items must be identified on the

quote and invoice

Expand the scope of your offerings through:

Modifications

Additional GSA Schedule contracts

Contractor Teaming Arrangements (CTAs)

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Trade Agreements Act (TAA)

Must ensure offerings are manufactured in a TAA

compliant country

Applicable to all Schedule contracts (including services)

TAA compliant countries can be found under FAR 25.003

Review your pricelist and GSA Advantage!® file for

accuracy and possible noncompliant items

Notify your PCO if noncompliance is uncovered

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Basis of Award

Discount relationship which predicates your GSA

pricing

Found on the Standard Form 1449, Final Proposal Revision

Letter, or subsequent modifications (Standard Form 30)

Must be maintained to comply with the Price Reductions

Clause (GSAM 552.238-75)

Adverse changes are referred to as “price reductions”

Price reductions should be reported to the PCO within 15

calendar days

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Other Compliance Concerns

Labor qualifications

Environmental attributes

Delivery

GSA Advantage Pricelist

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Questions?

Carrie L. Cuevas

Master Industrial Operations Analyst

GSA, Federal Acquisition Service

(281) 382-2189

Carrie.Cuevas@gsa.gov