Any new presidential administration brings changes to the world of federal contracting, and the Trump Administration is no exception. It has been clear from the outset that one of the major priorities of this administration is eliminating government waste, leading to a slew of contracting-related Executive Orders and policy memoranda. With so many changes occurring, it can be hard to keep up. As important as it is to pay attention to new regulations and policies, it is also important to take note of regulations and policies that haven’t changed in the GSA Multiple Award Schedule (MAS) Program and are still applicable to contractors.
One area where regulations and policies remain largely unchanged is in the field of subcontracting. When the Trump Administration began passing Executive Orders (EOs) aimed at dismantling policies related to diversity, equity, and inclusion (DEI), there was some speculation as to whether this would impact small business subcontracting requirements for GSA Schedule holders. However, small business subcontracting requirements for all socioeconomic categories remain in place. While it’s entirely possible that the Trump Administration may think these socioeconomic categories are contradicting the DEI EO, Executive Orders cannot get rid of them. The socioeconomic categories and contracting goals are established by Congress, meaning it would require an act of Congress to alter or do away with them.
Since small business subcontracting goals are still in place, that means that subcontracting reporting requirements are still in place as well. All GSA contractors are required to submit a Summary Subcontracting Report at the end of the federal fiscal year, due November 14th. Contractors with an Individual Subcontracting plan also have to submit two Individual Subcontracting Reports—one at the same time as the SSR, and one midyear, due May 15th.
Subcontracting reports aren’t the only reports that contractors are still required to submit—sales reporting is another administrative area that hasn’t seen cutbacks in the Trump Administration. GSA contractors are required to report their GSA sales either monthly or quarterly, depending on whether their contract is subject to Transactional Data Reporting (TDR) or Commercial Sales Practices (CSP).
TDR contractors report on 12 (16 including the 4 optional elements) transactional data elements (such as price, part number, order date, and shipped date) every month, while CSP contractors report only aggregate sales by Special Item Number (SIN) every quarter. One change that has affected sales reporting is the expansion of the TDR program. TDR is now mandatory for all contracts with TDR-eligible SINs, and all product SINs have been added to TDR. This change, however, has been long planned as the GSA is currently in the midst of expanding TDR to all SINs.
In addition to sales reporting, the minimum sales requirement also has not changed. GSA contractors are required to have at least $100,000 in sales during the base period of their contract, and $125,000 in sales during each subsequent option period.
While sales reporting requirements and sales minimums have not seen formal changes, we may see more strict enforcement (especially of the minimum sales requirement). As the federal government seeks ways to eliminate waste, underperforming or noncompliant contracts have a higher chance of being cancelled. This is why it is crucial for contractors to ensure that they are submitting timely, accurate sales reports.
One of the earliest actions taken by the Department of Government Efficiency (DOGE), the agency created by the Trump Administration to “maximize governmental efficiency and productivity”, was mass firings and layoffs across the entire federal government, and GSA in particular. Hundreds of GSA employees, including Contracting Officers, were fired, laid off, or accepted early retirement in the first wave of DOGE-inspired cuts. Given the steep reduction in workforce combined additional responsibilities for GSA, it wouldn’t be out of the question to wonder if there were plans for the offer review process to be changed or streamlined in some way.
This is not the case, as offers are still assigned to individual Contracting Officers (COs) or Contracting Specialists (CSes) for review. The only difference is that, with fewer COs and CSes available to do the same amount of work, wait times for offers to be reviewed are significantly longer.
However, this reduction in workforce has proved to be somewhat temporary, as many of those who lost their jobs during the initial purge have been asked to return to work. All in all, while GSA did not make any formal changes to the review procedure due to Trump Administration actions, the frequent staffing changes have impacted timeline for many contractors.
While this blog covered areas of the GSA that haven’t changed under the Trump Administration, there were plenty of areas that have been affected by Executive Orders and policy changes. These changes have impacted both prospective contractors and current schedule holders, albeit in different ways. If you want to know more about recent changes to the GSA, reach out to us. One of our expert consultants will be happy to help.