Best Practices for GSA Invoicing and IFF Reporting
GSA Schedule | 5 Min Read
As a contractor for the General Services Administration (GSA), you know that a key part of contract compliance is regularly reporting your sales and paying the Industrial Funding Fee (IFF). Whether you report on a monthly or quarterly basis, it’s essential you have a consistent and accurate invoicing process so you can be certain you are reporting the correct sales.
To ensure that contractors are compliant with their sales reporting process, GSA will conduct Contractor Assessments on a semi-regular basis. During these assessments, an Industrial Operations Analyst (IOA) will analyze your sales practices and reporting history to ensure you are compliant with GSA terms and conditions.
There are two types of visits: Annual Assessments and End of Term Assessments. Annual Assessments will occur every year for contractors that produce more than $150,000 in sales. End of Term Assessments occur for all contractors approximately 12 months prior to their contract extension. Here’s what you need to know about these assessments and how you can properly prepare your GSA invoices and sales reporting for them.
The Contractor Assessment Process
The Contractor Assessment process starts when your IOA reaches out to you to schedule a date and time for the assessment. They will typically request some standard forms ahead of time, such as your GSA pricelist, modification documents, and key terms and conditions documents, such as your SF-1449. The IOA will also request a sampling of commercial and federal invoices, which they will review prior to the assessment.
The Annual Assessment
During an Annual Assessment, the IOA will focus on the following issues:
- Are you correctly tracking and reporting your GSA sales?
- Are you correctly applying your prompt payment discounts?
- Are you correctly pricing your GSA Schedule services or products to applicable GSA eligible entities?
- Are your offerings compliant with the Trade Agreements Act (TAA)?
- Are you complying with the minimum requirements for your awarded labor categories?
End of Term Assessment
During an End of Term assessment, your IOA may cover additional items, such as:
- Have you maintained the price/discount relationship with your Basis of Award (BOA) customer?
- Do your offerings fall within the scope of your contract?
- Are you compliant with E-Verify reporting requirements?
- Is your GSA Advantage! catalog accurate and up to date?
- Is your GSA awarded terms and conditions pricelist up to date?
The IOA will discuss any outstanding issues and will provide instructions in the event that any corrections or follow-up actions are needed. After the assessment, you will be issued a Contractor Assessment Report (CAR), which serves as a summary of the assessment. You can learn more about the specifics of Contractor Assessment Visits in GSA's Contractor Assessment Reference Guide.
The Basics of GSA Sales Reporting
While the purpose of Contractor Assessments is not to get you in trouble if you are in aren’t complying with your sales reporting requirements, it’s essential you are prepared for these visits. Repeated and unaddressed issues could lead to trouble for your GSA Schedule down the line. The best way to ensure you get a good score on your Contractor Assessment is to have a consistent and accurate reporting process for your GSA sales.
To start, you’ll need to understand the information that is required of you and how often you need to provide it. Contractors must file their sales reports through the FAS Sales Reporting Portal. If you are not subject to Transactional Data Reporting (TDR), then you are required to report your GSA sales on a quarterly basis, and you only need to provide the dollar amount of GSA sales for each awarded Special Item Number (SIN) on your contract.
Contractors who are subject to TDR are required to report their GSA sales every month, and they are required to report more information about their sales. This includes:
- Purchase order number
- Specific line item sold and associated SIN
- Unit cost of line item sold
- How many line items were sold
- End customer (federal, state, or other)
All contractors must remit the Industrial Funding Fee (IFF) on a quarterly basis, which accounts for .75% of GSA sales. If you are using the Order Level Materials (OLM) SIN, these items are still applicable to the IFF. If you add Open Market items to your task order, note that these are not considered GSA sales and should not be reported.
GSA recognizes a sale recorded in a manner consistent with your established commercial accounting practice. You may decide to report GSA sales upon:
(1) Receipt of order
(2) Shipment or delivery
(3) Issuance of an invoice
It’s important to remember that you must always report your GSA sales, even if your sales are $0.
Best Practices for Sales Reporting
Prior to your assessment, you will be required to send your IOA a sample of your GSA invoices. To ensure these are clear, it’s important you have a good process implemented for any invoice under your GSA Schedule. Work with your accounting team to ensure that these practices are in place:
- Have the following noted on every invoice: GSA Contract Number, DUNS Number, SIN, Part Number and/or Service Name and Description.
- Do NOT charge above the GSA price, but feel free to give spot discounts. Spot discounts can be given either on a service or line item, or on the order as a whole. Spot discounts will not affect your GSA pricing.
- Ensure that the GSA prompt payment and volume discounts are noted on quotes, proposals, contracts, and invoices. If your contracts call for a volume and prompt payment discount but this is not stated on the invoices, you may be held responsible and need to credit the government at a later date.
- If you include Open Market items on a GSA order, make sure you mark the items as Open Market to avoid overpaying the IFF fee.
By having a good understanding of GSA sales processes and having these best practices in place, you can be well prepared for your Contractor Assessment Visit.
Are You Ready for Your Next Contractor Assessment?
Implementing good processes for sales tracking and reporting is an essential part of contract maintenance. By keeping ahead of these requirements, you can be well-prepared for your Contractor Assessment visit. These can be overwhelming and confusing even for the most experienced contractors. Thankfully, we are here to help if you need it. We have extensive practice in helping our clients with sales reporting and guiding them through CAVs, sales reporting, and invoicing. Contact our team today for more information.