GSA Schedule contractors must be compliant with multiple rules and regulations throughout their contracts’ duration, and any agency-specific policies as they complete task orders. By having a GSA Schedule contract awarded, a company is not guaranteed to receive sales. A GSA Schedule is a non-funded contract. To earn revenue, contractors will need to compete to win task orders. For contractors who sell products, federal buyers will also have the opportunity to purchase directly from contractors’ available offerings through GSA Advantage! if they are under the Mirco-Purchase Threshold (MPT).
Requirements for task orders will likely differ greatly between ordering agencies depending on the products or services being solicited. In this blog, we will identify requirements for GSA Schedule contractors to be aware of at the task order level and overall contract level.
GSA eBuy is a portal for GSA Schedule contractors to search for and bid on contracting opportunities released by federal buyers. Agencies will release a Request for Proposal (RFP) or Request for Quote (RFQ) to procure specific services or items from contractors. In the eBuy system, contractors will only have access to the RFPs/RFQs released under the Special Item Numbers (SINs) they currently have awarded. GSA Schedule contractors can review available opportunities and submit a response to the ones that align with their GSA Schedule contract’s offerings to potentially win the award.
While these steps appear relatively straightforward, it is important to review the actual RFP/RFQ document included with the notice to ensure you meet the agencies’ requirements. Key components of an RFP often include the following sections: instructions, evaluation criteria, statement of work (SOW) or performance work statement (PWS), contract clauses, and attachments.
To recap: At the contract level, you are simply gaining access to the Multiple Award Schedule (MAS) program. To win task orders and generate sales, contractors will need to review RFPs available in the eBuy system other solicitation sites like SA.gov and submit a competitive response. Contractors will utilize their awarded services or products at the contract level in their RFP responses.
In the following sections, we will discuss a few common compliance concerns that differ or are similar at the task order and contract level.
The period of performance for a GSA Schedule contract is a five-year base period with three five-year option periods. At the contract level, contractors are required to meet the GSA minimum sales requirement to avoid contract cancellation. As stated under I-FSS-639 Contract Sales Criteria in the MAS Solicitation, contractors must exceed $100,000.00 in sales during the base period. For each subsequent 5-year option period, contractors need to exceed at least $125,000.00 in sales. At the task order level, contractors do not need to meet a minimum sales requirement; however, the sales generated from task orders will help contractors reach the minimum requirements mentioned above.
This requirement for GSA Schedule contractors has been enforced frequently in the past months to align with the Trump Administration’s initiatives for GSA to increase efficiency and reduce costs, resulting in many contract cancellations for contractors failing to meet the minimum sales requirement.
When completing task orders, GSA Schedule contractors have an opportunity to add services or products that were not originally awarded to their contract through the Order Level Materials (OLM) SIN. These additional resources help contractors provide a complete solution at the task order level and should be reported as GSA sales.
If you would like to add labor categories, fixed price services, or products to your current awarded offerings rather than just for a specific task order, you will need to complete an addition modification at the contract level. When services are approved and awarded by your assigned contracting officer (CO), you will be able to leverage these labor categories or fixed price solutions when responding to a Request for Information (RFI), Request for Quote (RFQ), or RFP in GSA eBuy. For products that are added through a contract level modification, these items will be available for buyers to purchase directly from GSA Advantage!.
The prices for services or products initially awarded to your GSA Schedule or added through contract level modifications represent ceiling rates. For example, if a contractor was awarded an hourly rate of $150.00 for a labor category, then they cannot charge ordering agencies above $150.00 per hour for that role. If desired, contractors can offer discounts on their ceiling rates at the task order level to be competitive. Your awarded contract level prices will not be affected when you offer a discount at the task order level.
When submitting a GSA Schedule offer, you do not have to worry about an in-depth review of your company’s IT infrastructure. This would be a concern at the task order level and requirements can differ between agencies.
When submitting a GSA Schedule offer, businesses are required to certify compliance with Section 889 (a)(1)(A) and (a)(1)(B) of the John S. McCain National Defense Authorization Act of 2019. GSA Schedule offerors are prohibited from selling covered telecommunications equipment to government buyers and using this type of equipment while performing work awarded under a task order.
At the task order level, GSA Schedule contractors may encounter agencies requiring solutions with certain cybersecurity program certifications. For example, The Federal Risk and Authorization Management Program (FedRAMP) is a standardized process for assessing the security of cloud computing solutions and determining authorization for federal agencies’ use of the service. While the IT Category Attachment for the MAS Solicitation does not specify that FedRAMP certification is required for GSA Schedule contractors’ cloud services awarded under the Cloud SIN, federal agencies may specify this requirement in an RFP at the task order level.
Based on National Institute of Standards and Technology (NIST) 800-171 guidelines, Cybersecurity Maturity Model Certification (CMMC) is an additional cybersecurity requirement that agencies may request in task orders for information protection purposes.
To conduct business with the federal government, contractors will need to maintain an active account on the System for Award Management (SAM) website or SAM.gov. A SAM registration is required for businesses to obtain a GSA Schedule contract and to perform work during task orders.
At minimum, contractors will need to renew their SAM.gov account at least once a year. You should be updating your SAM.gov registration any time there is a change with your business, such as your company’s physical or mailing address, points of contact, and banking information. Bank account routing information isn’t necessarily important to have a GSA Schedule awarded, but at the task order level, this is how agencies will know how to pay you for the work being performed.
You will also certify or respond to many of the same Federal Acquisition Regulation (FAR) clauses within SAM and within the offer submission portal, eOffer, when you are ready to submit your GSA Schedule offer. For example, you will be asked to certify compliance with covered telecommunications equipment/services in both your SAM account registration and offer submission.
It is important to monitor any changes relating to maintaining your GSA Schedule contract at the contract level and while completing task orders; GSA occasionally releases updates to the MAS Solicitation through Refreshes. Solicitation Refresh #30 is expected to be released in November 2025. With this Refresh, GSA plans to incorporate numerous clauses associated with the Revolutionary FAR Overhaul (RFO). This will result in many current Solicitation clauses being replaced or removed to align with the RFO initiative. Additionally, GSAM Subpart 538.71 will be the governing provision for Federal Supply Schedule (FSS) ordering procedures, which impacts contractors at the task order level.
To stay up to date with the changing federal marketplace, make sure to monitor our blog. Our consultants are also available to help you ensure your GSA Schedule remains compliant at the contract level for task order success.