Congratulations on your GSA Schedule award—now that you have your contract, you’re ready to begin the process of maintaining compliance. This is essentially the “scope of contract,” which may seem vague to you at first. We advise all new contractors to begin familiarizing themselves with the rules and regulations of holding a GSA contract. As consultants, we can’t stress enough how important it is to look after your Schedule once it’s been awarded. To help you prepare for this process, let’s discuss why scope of contract is important and what you can do to maintain GSA Schedule compliance.
Why is Scope of Contract with Your GSA Schedule Important?
Scope of contract refers to the proper use and maintenance of your GSA Multiple Award Schedule (MAS) contract (also referred to as GSA Schedule and GSA contract). Failing to comply with rules and regulations may result in penalties, fines, or even termination of your contract, although the last one is more extreme. To avoid these occurrences, ensure that you’re following the rules by maintaining compliance. We listed some best practices below to help you get started.
Sales Reporting: Make Sure You Know What is Considered a GSA Sale
All GSA Schedule sales have to be reported even if the amount is $0. Quarterly sales are due 30 days after the end of the quarter, meaning they are due the 30th of January, April, July, and October. If you opt into Transactional Data Reporting (TDR) instead of Commercial Sales Practices, you are required to report your sales monthly. Once a quarter, you are also required to pay the Industrial Funding Fee (IFF), which is 0.75% of all your sales for that quarter.
But the main tip here is to make sure you are only reporting sales through your GSA Schedule. If you report more, you’ll end up paying a higher IFF. But how do you know what is considered a GSA sale? A product or service is considered a GSA sale when:
- GSA contract number is stated on the purchase order or task order
- Ordering information and terms are the same as your GSA Schedule
- Pricing is at or below the GSA Schedule price
- Government buyer made contact with you through GSA Advantage! or GSA eBuy
- Products listed under the Order Level Materials (OLM) Special Item Number (SIN)
- There is no indication of another contract vehicle in place
- Product or service is on your GSA Schedule
Since open market items don’t fall under GSA Schedules, they are not reported. Be sure to separate contract items and open market items when you’re reporting through the FAS Sales Reporting Portal and clearly mark open market items on an order. If you need help or guidance on how to report your sales, the GSA Vendor Support Center (VSC) is available to get you started.
Understand What Open Market Items Are
Open market items are products companies offer that are not within the scope of the contract. Therefore, if an open market item is purchased, it’s not subject to the same terms that are associated with a GSA Schedule. This all ties in with the Federal Acquisition Regulations (FAR), which establishes the rules federal government and contractors have to follow for purchasing goods and services through contracts.
Keep Up with GSA Modifications
If you need to make changes to your GSA Schedule from your address or Point of Contact, to adding a new product or changing a product description, you will need to submit a GSA Schedule modification. This is especially important if you change your pricing. You want to make sure your GSA Schedule is updated and reflects all the correct product and service descriptions, pricing, terms and conditions, and company information. Modifications can take some time to be approved depending on the type of mod you are submitting, so we suggest you don’t wait too long to get started.
Continually Check for Trade Agreements Act (TAA) Compliance
Your company’s contract items along with their descriptions will be displayed on GSA Advantage! throughout the life of your Schedule. A good practice in maintaining compliance is ensuring that your products and services remain Trade Agreements Act (TAA) compliant. Although you already had to do this before you received your GSA contract award, you’ll need to keep it up throughout the life of your contract.
Some companies may not keep a close eye on whether a product or its component has a manufacturer change and that can get them in trouble. We suggest you have a system in place to routinely monitor this. Check out the full list of countries that are accepted and make sure your company’s items are falling into the correct category. If you’d like to learn more about TAA compliance, be sure to check out our blog on TAA FAQs.
Make Sure Your Team is Briefed On All GSA Schedule Requirements
Whether you are only selling a few items or you are offering hundreds with a whole sales team, it’s important your team is properly educated and trained for GSA Schedule compliance. This applies to determining GSA sales, keeping up with changes to admin, products/services, etc. so you can complete a modification, and keeping up with TAA compliance. Your team should be well aware of the GSA Schedule pricing rules, when a change constitutes a formal modification, and what the basic parameters of TAA compliance are. Someone should also be in charge of GSA sales.
Keeping Up with Compliance
This is a lot to manage—we completely understand. As GSA contractors ourselves, we know there are several compliance rules to follow and if you’re a small company with little bandwidth and are lacking a team of GSA contract professionals, it can be difficult to keep up.
Although we hope this blog helped you get a better idea of how you can maintain your GSA Schedule, we are here to help you if you need additional support. If you’d like to learn more about compliance, feel free to read our blog “How to Maintain Your GSA Schedule Contract: An Essential Checklist”. If you want to learn more about how our consultants can help you keep track of your contract, feel free to reach out to us.
