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The GSA Schedule acquisition process takes a significant amount of time to complete from start to finish, usually multiple months at the least. In addition, with how busy GSA Contracting Officers (COs) can be, even modifications to existing GSA Schedules are not guaranteed to be processed quickly, which causes an issue if an urgent opportunity from a procuring agency slips you by because you don’t yet have the relevant items added to it. Thankfully, for some contractors, there is a way to speed up the review of offers or modifications under the GSA Multiple Award Schedule (MAS) Program.
For companies looking to expedite the processing of offers or modification awards, you should look into GSA’s FASt Lane Program, as it offers a quicker path for approvals for qualifying vendors. Recent changes have opened up the FASt Lane option to more offerors. However, it's important to note that there are still requirements that will effectively narrow the pool of offerors who can use it in their Schedule acquisition process, and the eligibility has not changed for modifications.
In this blog post, we will outline and discuss the current requirements for the FASt Lane Program and help you determine whether your business might qualify under the updated guidelines.
What is the FASt Lane Program?
The FASt Lane Program enables eligible GSA MAS contractors to experience shorter processing times for contract actions, including GSA Schedule acquisition and modifications. Under this program, contractors can have their GSA Schedules awarded on a faster timeline than the standard GSA MAS acquisition process. While we can’t provide a guaranteed timeframe for government processes, this program does significantly reduce the time that’s involved.
On the post-award side of things, it also accelerates the modification process; for instance, adding new products and services to your MAS contract can take just 24 to 48 hours for approval. Agencies benefit from this program as well, as it provides them with quick access to emerging technologies and innovative offerings.
It makes sense for GSA Schedule offerors and holders to consider this option. However, it's important to be aware of the various requirements that must be followed. Specifically, there have been some recent changes to the eligibility criteria as of Solicitation Refresh #33. Below, we describe those updated requirements.
Do You Qualify for the FASt Lane Program?
As of Solicitation Refresh #33, if you are submitting an offer for a Multiple Award Schedule, you can submit a FASt Lane offer under any Large Category (provided you meet the other requirements listed below). If you are an existing Shedule holder looking to submit a FASt Lane modification, you must be assigned under the Information Technology Category (ITC) and be assigned an ITC contracting officer. If your Schedule has ITC SINs but not an ITC contracting officer, you unfortunately will not be eligible.
For modifications, only ITC Special Item Numbers (SINs) can be submitted in eMod. No other MAS categories or non-ITC SINs are FASt Lane eligible.
If your company checks one of the boxes above, there are additional requirements to consider. To participate in FASt Lane for both offers and modifications, you must:
- Be associated with a FASt Lane-eligible initiative:
- Technology and IT solutions initiatives
- Supply chain and logistics initiatives (SCRIPTS BPA – Supply Chain Risk Illumination Professional Tools and Services)
- Other MAS initiatives, across any category, as identified to GSA by the customer that may arise
- Submit a written request from a federal agency ordering activity: This takes the form of a letter that demonstrates a compelling need for your company to participate in FASt Lane to support the agency’s requirements and must come from, and be signed by, the Contracting Officer responsible for the procurement.
GSA has provided a sample “FASt Lane Expansion for Customer Agency Requests” document that the procuring agency’s Contracting Officer can use as an example on their main FASt Lane webpage. The purpose of this request is basically to establish the compelling need for why the offer or modification needs to be expedited.
How the FASt Lane Program Operates
One of the main goals of the FASt Lane program is to provide agency customers with direct access to vendors offering new and emerging technologies. As you proceed with the program, there are two important factors that you’ll need to be mindful of. First, all vendors need to be in close contact and responsive to their designated GSA Contracting Specialist or Contracting Officer.
Second, it’s extremely imperative to ensure that all technical evaluations are completed and any necessary supporting documentation is included and submitted directly to the eOffer/eMod system. Email exchanges with Contracting Officers and Specialists are not the proper method for officially submitting modifications or offers, though they may be required before formal submission of a modification, depending on the technical requirements of SINs included.
Now that you know that your company is ready to use the program, let’s now take a closer look at the required documents to successfully navigate the FASt Lane process, as these requirements can be easily overlooked.
Required Forms and Documents for FASt Lane
FASt Lane will require the following documents to process your business as quickly as possible through the system. If you are a large business involved in any subcontracting plans, you may be asked for additional documentation or financial statements beyond the scope of this checklist. If you need clarification on what each document entails or how to obtain them, please don’t hesitate to reach out to our consulting team.
When submitting a FASt Lane offer through eOffer, you must include:
- FASt Lane Eligibility Checklist, downloadable from GSA’s FASt Lane webpage.
- All documents and responses per the solicitation requirement. No requirements are formally waived under FASt Lane procedures.
- Any written requests from the agency asking you to participate in FASt Lane to support their IT requirements.
When submitting a modification, the same requirements apply, but you must also keep in mind that if your FASt Lane eligible initiative includes a SIN requiring a technical review, the technical review for that SIN must be completed before submitting the modification through eMod. Once your technical documents are reviewed and approved by the GSA CO, you can submit a FASt Lane request through eMod along with the required FASt Lane Eligibility Checklist and documentation that supports the completed and acceptable/passed technical evaluation.
Several FASt Lane SINs and BPAs require additional information or technical review before formal modification submissions. Check the FASt Lane Eligibility Checklist to confirm whether or not there are specific instructions for the SIN you would like to include in your FASt Lane modification.
FASt Lane Deadlines
Once submitted, there are deadlines within which to respond to any clarifications from your Contracting Officer to maintain FASt Lane eligibility. For offers, FASt Lane participants must respond within 24 hours of receiving any inquiries or requested information from GSA COs, or the eOffer will lose FASt Lane eligibility. For modifications, FASt Lane participants must respond within 2 hours of receiving any inquiries or requested information from GSA contracting officers, or the eMod will lose FASt Lane eligibility.
FASt Lane Eligibility Checklist
As mentioned above, this checklist is required for FASt Lane offers or modifications and requires proof of opportunity, such as a Request for Quote (RFQ), Sources Sought Notice, Request for Information (RFI), or agency provided timelines for non-published acquisition initiatives. You will notice that this checklist will request information on the specific opportunity that requires you to submit a FASt Lane action as well as instructions for how to submit documentation for technical reviews for specific SINs.
We highly recommend providing as much information as possible in your technical documents to give a comprehensive overview of your business’s eligibility and capabilities. Once all technical documents have been successfully reviewed, you can proceed to submit your FASt Lane request through eMod. Please ensure your communication during the process is prompt to avoid issues or delays in approving your modification, or you could lose your FASt Lane status.
Need Assistance with the FASt Lane Program? We’re Here to Help!
We understand how important it is for you to quickly obtain and maintain your GSA Schedule. Not fully understanding the process can cause delays. If you have questions about your eligibility for the FASt Lane Program or need assistance with enrollment, please don’t hesitate to reach out to one of our consultants. Additionally, if you need to contact GSA regarding any questions or concerns, FASt Lane has its own dedicated mailbox for inquiries at fastlane@gsa.gov.
