Recently, the General Services Administration (GSA) released a webinar covering policy landscape in the government Q2 of FY24. During this webinar, they explored various topics relevant to current and prospective GSA contractors. In this blog, we’ll discuss changes that were implemented in Q2 FY24 and what’s expected in Q3 FY24 (April through June), such as robo mods, TDR changes, and new regulations regarding Supply Chain Risk Management (SCRM).
GSA’s Robo Mods
Robo mods may be new to some contractors, but they’ve been around for about five years now. Robo mods are a fast and automated process to identify and solve contract compliance concerns. The purpose of these mods is to help GSA stay compliant with executive orders, Federal Acquisition Regulation (FAR) clauses, GSA and FAS policy, and it protects the GSA brand as a trusted source of supply.
Robo mods initiate delete mods to:
- Remove products that are noncompliant with the Trade Agreements Act, or those that inaccurately list the country of origin as the U.S.
- Remove essentially the same products as AbilityOne items, since AbilityOne products are mandatory purchase items for federal customers.
- Commercial products that have been deemed essentially the same as AbilityOne can't be offered on federal contracts.
- Remove unauthorized products that contractors aren't authorized to sell based on information that's provided in the verified products portal.
- Another category of Robo mod deals with removing products that are prohibited for national security reasons.
- This includes Kaspersky Lab covered articles, covered telecommunications equipment such as 889, Section 889, and prohibited product under a FASCSA order.
What to Do if You Receive a Robo Mod
If you’ve recently received a unilateral robo mod, you may be wondering what actions to take. First, make sure you don't resubmit these products. The only time you should ever resubmit these products is if you have proof that an error has been made, and that evidence has been provided to GSA and provided by the CO.
Second, you need to remove the non-compliant products from your GSA contract pricelist, delete from GSA Advantage!, and update your Price Proposal Template (PPT), so it reflects all the correct products for when you’re ready to make changes to your contract. To avoid robo mods in the future, be sure to maintain adequate internal quality control to keep noncompliant products from showing up on GSA Advantage!.
If you fail to take corrective action, you could face the consequences of temporarily having your access to GSA eTools suspended. Without these tools, it’s difficult to be a successful GSA contractor. So, it’s important to ensure that you’re taking the right steps to constantly update your contract and ensure you are complying with all government regulations.
Transactional Data Reporting (TDR) Updates
While only some contractors are eligible for Transactional Data Reporting (TDR), GSA plans to extend this program to all contractors. There are two types of reporting, TDR and Commercial Sales Practices (CSP). The easiest way to determine if you are TDR is if you report your GSA sales monthly. Conversely, contracts that fall under CSP are required to report on a quarterly basis. In Q2, GSA announced new reporting requirements under TDR to provide better insights for GSA and industry partners.
What Does TDR Do for the Industry?
- It increases the value of holding a GSA contract.
- It provides better insight to be successful.
- It makes it easier and more cost effective to do business compared to legacy models.
TDR continues to evolve and improve its data quality to best answer the fundamental business question, “What are customers buying?” In doing so, they have recently implemented strengthened validations to ensure that bad data doesn't reach GSA’s systems and tools. Further, GSA is launching Industrial Operations Analyst (IOA) assessments with a new TDR question in FY24 to get feedback and adjust the program accordingly.
Supply Chain Risk Management (SCRM)
Supply chain management plays a critical role within GSA and involves assessing and mitigating various risks, such as disruptions in the availability of critical resources, cybersecurity threats, and compliance issues.
During the policy review, GSA highlighted some of the changes associated with Executive Order (EO) 14028, “Improving the Nation’s Cybersecurity,” such as changes to National Institute of Standards and Technology (NIST) and Cybersecurity & Infrastructure Security Agency (CISA) guidance to identify practices that enhance the security of the software supply chain.
Prohibition of certain semiconductors and products and services was another area of focus. More specifically, the National Defense Authorization Act (NDAA), contains two specific prohibitions regarding the procurement and the use of foreign semiconductor products and services, specifically Chinese companies and other foreign countries of concerns that will come into effect in December of 2027.
Staying Updated and Informed in the GSA World
Keeping up with GSA regulations and contract compliance can be difficult if you don’t have the bandwidth. To stay on top of future government contracting updates, you can sign up for our weekly blog email and monthly newsletter. Our team is well-versed in contract compliance and can assist you in navigating the modification process for your contract. Whether you need assistance in crafting your GSA offer, seek guidance on reporting procedures, or have any GSA related questions, our consultants would be happy to help you.
