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GSA Ordering and Contract Compliance for New Schedule Holders
By: Courtney Fairchild
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GSA Ordering and Contract Compliance for New Schedule Holders
Ordering Process, Maintenance and Administration of GSA Schedules
WIPP is a national nonpartisan public policy organization, advocating on behalf of nearly 4.7 million businesses women
representing 78 Coalition Partners. WIPP provides timely economic policy information and identifies important trends and
opportunities to its membership.
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GSA Ordering and Contract Compliance for New Schedule Holders
Ordering Process, Maintenance and Administration of GSA Schedules
Courtney FairchildCo-Founder and President
Global Services
GSA Schedule Ordering
Ordering Methodologies
FEDERAL ACQUISITION REGULATION 8.405-1
GSA ESTABLISHEDPROCEDURES FAR 8.405-2
PRODUCTS SERVICES
Orders For ProductsOrders For Products
Under $3,000 – The Government Can Order From Any Schedule Contractor
Over $3,000 and Under the Simplified Acquisition Threshold ($150,000) – The Government Should Get Three Quotes Before Ordering
Over the Simplified Acquisition Threshold – The Government Follows the Same Procedures for Orders
Over $3000, Looks at Additional Pricelists and Seeks Price Reductions Before Ordering
Orders For ServicesOrders For Services
PrepareRFQ
TransmitRFQ
Award
GSA’S INSTRUCTIONS TO GOVERNMENT
Outlines 3 simple steps
Step 1: Preparing the RFQ
– Work to Be Performed
– Location of Work
– Period of Performance
– Applicable Standards
– Delivery Schedule
– Acceptance Criteria
– Special Requirements
Government or Contractor?
Prepare a Performance Based Statement of Work That Outlines, at a Minimum:
Step 2: Transmitting the RFQ
Send to 3 - If Order Is Between $3,000 and the Simplified Acquisition Threshold
Orders Over the Simplified Acquisition Threshold Should Be Sent to Additional Contractors
Step 3: Making the Award
The Ordering Office, at a Minimum, Should Document Orders by Identifying the Contractor the Services Were Purchased From, the Services Purchased, and the Amount Paid
If Other Than a Firm-fixed Price Order Is Placed, Such Documentation Should Include the Basis for the Determination to Use a Labor-hour or Time-and-materials Order
As the Contractor You Must Be Prepared to “Hand-hold” the Government Through this Process
GSA Services Order Summary
Under $3,000 - Order from any GSA Schedule holder Over $3,000 - Evaluate 3 RFQs - Make Best Value Award SOW is between Ordering Agency and Contractor
(GSA is not involved in any way.)
Schedule 1
Schedule 2
Schedule 3
AGENCY
Task
Who?
CONTRACTOR
T.O.
Best Value
GSA 0.75%
Managing the Order Process
Same Person?
Activity/Steps ContractorCustomer End
UserCustomer Contracting
Office
1. Develop Performance Based SOW X X
2. Define Evaluation Factors X X
3. Develop Selection Procedure X X
4. Prepare RFQ X X
5. Identify Alternate Contactors X X X
6. Decide Small Business Reservation X
7. Issue RFQ X X
8. Submit Quotation X
9. Select Best Value Contractor X X
10. Issue Purchase Order X
Important Information on GSA Schedule Sales
Eligible Users
GSA Order ADM4800.2E (See Appendix B) Three categories of customers:
– Executive Agencies– Other Eligible Users– International Organizations
Other Considerations– You are obligated to accept orders that are below the Maximum
Order threshold from all executive agencies– Maximum Order threshold—not a ceiling.
You are not obligated to sell to those outside the executive branch– Return orders within 5 days– Return orders within 24 hours if made with a purchase card
What is a Schedule Sale?
When an order issued by an eligible user fits within MAS parameters, it is considered to be a Schedule sale unless the ordering activity indicates otherwise– Contracts clearly awarded under FAR parts 12, 13, 14, or 15– Establish with your customer at time of order placement whether a sale
is being conducted under or outside the Schedule MAS Parameters
– The GSA contract number is stated on the purchase or task order– The ordering information and terms are the same as your GSA contract– The customer made contact with you through GSA Advantage! or e-Buy– The customer pays with the government purchase card– The pricing is at or below the contract price– The order is over the $3000 micro purchase threshold and there is no
indication of any other procurement vehicle being used
Sales Tracking System
Must be auditable by GSA to include:– Records, identifies, values, and summarizes all transactions
– Reports all transactions within the proper period
– Retrieves data easily
– Separates schedule sales from other federal sales and
commercial sales
– Automation is not required but may be necessary
– Must Track by Special Item Number (SIN)
– Separate out State/Local from Federal Sales
– Consistent
Sales Reporting & IFF Payment
http://72a.gsa.gov All schedule sales must be reported in U.S. dollars and rounded to
the nearest whole dollar Sales must be reported on a quarterly basis Sales reports must be submitted by you within 30 days after the
quarter ends Even if you have no sales for the quarter, you must still file a $0
sales report The Industrial Funding Fee (IFF) must be paid by you on a quarterly
basis and is paid as a percentage (.75%) of ALL reported sales Method of Payment
– Credit Card– Electronic Check (Direct Debit)
Small Business Eligibility
Ordering Activity Contracting Officers May– Set Aside Orders or BPAs for Small Business Concerns
Listed in FAR 19.000(a)(3)– 8(a), HUBZone, Woman-Owned, Veteran-Owned, SDVOB,
Small Disadvantaged Business Concerns
Regulations Requires Contractors Only to Recertify Business Size When Exercising Option Instead of Annually– Currently Certified When GSA Proposal is Submitted– Recertification Not Required or Permitted Until First Contract
Option Has Expired
GSA Schedule Maintenance And
Administration
eOffer/eMod & Digital Certificates
eOffer & eMod are web-based applications that allow companies to electronically prepare and submit a MAS contract proposals and modifications, respectively, to FAS
Contractors are required to have a digital certificate for access into the eOffer/eMod applications and to sign the final documents electronically
eOffer & eMod are currently mandatory for all schedules. Check the Fedbizopps solicitation posts to see which apply
eOffer/eMod & Digital Certificates
Digital Certificates:– Asserts the identity of an individual– Create digital signatures which are verifiable.– Must be a ACES Level 3 certificate "Business Identity
Certificate"– Must be updated every two (2) years
Additional Information and Training on eOffer/eMod and Digital Certificates can be found http://eoffer.gsa.gov/
Additions/Deletions of Services/Products
Additions Will Require:– Pricing Justification - Historical Sales Data or Cost-buildup
Supported by DCAA Approved Rates, Commercial Pricelist
Deletions Can Be Done at Any Time By Simple Request
You Will Not Be Allowed to Delete a Service/Product and Then Later Add the Same Service/Product Back at a Higher Rate. Once You Submit Pricing Data to GSA Your Hands Are Largely Tied
Trade Agreement Act
Can be found in FAR 52.225-5
Only U.S.-made or designated country end products can be offered using your schedule contract
Items from non-designated countries must undergo substantial transformation into a new and different article of commerce with a name, character, or use distinct from that of the article or articles from which it was transformed.
Price Adjustments
Prices Must Be Held for Twelve Months From Date of Award for Most Schedules
Thereafter Adjustable 3 Times Each 12 Month Per Contract up to Max of 4 or 10%
Price Adjustments Based on 3 Possibilities:– Increase in Commercial Pricelist– A Market Price Indicator Negotiated Prior to Contract Award – Pre-negotiated Set Escalation Factor
You Can Always Lower Your Price
Reseller/Manufacturer Changes
As a Reseller Anytime a Manufacturer Changes Prices You Must Update Your GSA Schedule. In Some Cases If the Manufacturer Increases Pricing Substantially, You May Have to Pull the Product off Your Schedule If You Can Not Negotiate a Price Increase With GSA (or If You Are Within Your First 12 Months After Award.)
Outdated Pricing Is Cause for Contract Termination by GSA.
GSA Advantage!
GSA Advantage! is the Online Ordering Systems for GSA Schedule Purchases
All GSA Schedule Holders are Required to Post Their Current GSA Schedule Pricelists to the GSA Advantage! System
www.gsaadvantage.gov
GSA e-Buy
Contractors on GSA Advantage Are Automatically Registered on e-Buy
RFQs Can Be Sent to All or Selected Vendors by SIN
Contractors Respond Directly to RFQ on e-Buy– http://vsc.fss.gsa.gov/fss/global_verification.cfm?ID=ebuy
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