Unprecedented changes to the GSA’s CAV and OIG Audits are just around the corner. And while the GSA does make changes to their policies and procedures on occasion, this has more potential to be a disruptive force for so many contract holders.
Going forward, Contractors can expect to see the following from GSA:
1. Increase to Annual CAV (Contractor Assistance Visits)
Contractors with Sales over $150,000 will have special emphasis placed on them moving forward. These contractors will now be visited annually by GSA. The added frequency will include increased scrutiny. As part of this new audit initiative, the GSA will also start conducting 2 different types of visits:
- Standard Contractor Assessment Visit
- "Deep Dive" on reported contract awards along with a thorough IFF reporting audits.
2. Emphasis on "pre-visit access" to Master Accounting files
Perhaps most concerning is the increased demand for access to FULL Master Accounting files for review several weeks prior scheduled IG Audits citing that:
"...representative shall have access to and the right to examine any books, documents, papers and records of the Contractor involving transactions related to this contract for overbillings, billing errors, compliance with the Price Reduction clause and compliance with the Industrial Funding Fee and Sales Reporting clause of this contract."
Clauses cited to gain access to contractor data:
- CFAR 52.215-2: Audit and Records
- GSAM 552.215-71: Examination of Records by GSA (Multiple Award Schedule)
3. Greater emphasis on deleting Contractors with $0 Sales
Their goal is to clear-out the nearly 50 percent of contractors who are placing zero sales through their GSA Schedule.
Please take a moment to review and familiarize yourself with the GSA's Semiannual Reports to Congress. In addition, if you suspect that you have potential false claims or commercial sales practices violations, now is the time to get prepared and self-report.
