The GSA Schedule acquisition process can be difficult and lengthy - you have prepared and submitted your Multiple Award Schedule (MAS) offer, gone through negotiations and clarifications, and finally received your award. Now that you have a GSA Schedule, your top priority is to generate sales by marketing your products and services and finding government customers. However, you must also be sure to maintain your contract’s terms and conditions.
As a lead consultant with Winvale, I cannot emphasize enough how important contract maintenance is throughout the lifecycle of your GSA Schedule. If you fail to comply with GSA’s regulations, you risk having your contract cancelled.
We know it can be a lot to balance between finding contracting opportunities and making sure you are keeping up with your contract. So, we created a quick yet extensive checklist to help you keep track of your contract maintenance obligations.
GSA Contract Maintenance Checklist:
Accepting Mass Modifications
Mass Modifications are GSA initiated modifications to the MAS Solicitation. These are important for all contractors to review and accept regardless of what they are offering. The deadlines and outcomes of accepting Mass Modifications vary, but you should be on the look-out for any updates and accept them in the Mass Modification System as soon as you can. Generally, Mass Mods are due 90 days after the Refresh release. The most recent update to keep an eye on is MAS Solicitation Refresh #22, which was released in August 2024, and has major updates including expanding the Transactional Data Reporting (TDR) program to 67 more Special Item Numbers (SINs).
Updating Your Administrative Information
Throughout the life of your contract, you may have changes to your Point of Contact (Such as contract administrator, Order POC, Subcontracting POC), your contact information (phone, e-mail, fax), and your authorized negotiators. This information is updated through a contract modification. If you have the wrong address or POC, any interested government agencies may have a difficult time reaching you, and you are not complying with GSA Schedule regulations.
Updating Your Contract Offerings and Pricing
Anytime you need to:- Add products/services/SINs
- Delete products/services
- Make applicable part number and description changes
- Increase price
- Implement permanent price reductions
You’ll need to submit a formal contract modification just like with your administrative information. Your Contracting Officer (CO) needs to approve the request before you are awarded the modification. Modifications can take awhile to be approved, so it's important you are getting ahead of these changes and making them as they come up, especially if you are going after a timely contract opportunity. You don't want your GSA Schedule to have outdated pricing or product/service information.
Updating Your Commercial Sales Practices
If your contract is subject to Commercial Sales Practices (CSP), it’s important you disclose any updates to your CSP and make sure you do not make your Most Favored Customer (MFC) discount lower than the price you are offering government buyers. If your commercial customers are given a lower price, you are violating the Price Reduction Clause.
Updating Your GSA Advantage! Catalog
Once your GSA Schedule is awarded initially, you have 6 months to upload your catalog to GSA Advantage! and GSA eLibrary. After you submit a modification that has changed any part of your catalog, you must make those updates within 30 days. You are required in general to update your GSA Advantage! catalog at least once every two years.
Updating Your SAM Entity Registration
After registering your entity on the System for Award Management (SAM), you must update it annually to make sure all the information is correct. This is really important, so make sure to mark your calendar!
Trade Agreement Act (TAA) Compliance
Trade Agreements Act (TAA) compliance means the “final products” you sell through your GSA Schedule as a product manufacturer or GSA reseller cannot be made or "substantially transformed" in non-TAA compliant countries. To ensure you maintain TAA compliance throughout the life of your contract, we suggest you routinely ask your team the following questions:
- Have the products you sell had a change in their country of origin?
- Have countries been added/removed from the U.S. Trade Agreements Act(TAA)?
If you answered yes to one or both of these questions, you’ll need to reflect these changes in your GSA Schedule and ensure they are still within the scope of the TAA.
Ability One Compliance
Ability One is a program that employs people who are blind or have significant physical disabilities. GSA has a partnership with Ability One, so you must be sure your commercial products are not considered “essentially the same” as the products offered in the Ability One program. If you plan on adding new products to your Schedule, we suggest you review them carefully against AbilityOne's procurement list.
Price Reduction Clause Compliance
If you are opted into Commercial Sales Practices, are you maintaining your price/discount relationship with your Most Favored Customer (MFC)? This is important to maintaining contract compliance.
Contractor Assessments and End of Term Assessments
Before each Contractor Assessment or End of Term Assessment, you should be sure you are abiding by your contract terms and you have all your records organized so these visits go smoothly.
If you have everything in order for GSA, you are likely to have an easier and more productive visit.
E-Verifying Employees
The federal government requires all employees performing on federal contracts to be verified through the E-Verify web system. You can learn more about the requirements for federal contractors and how to enroll on the E-verify website.
Cybersecurity Requirements
Cybersecurity regulations change frequently in the government, especially if you are a contractor with the Department of Defense (DoD). You should ensure you are up to date with the recent changes and you are complying with the minimum requirements. Now that the DoD released the Final Rule for Cybersecurity Maturity Model Certification (CMMC), it's important you review these requirements in full if they apply to you and any future contract awards.
Invoicing Requirements
Do your GSA invoices include all the required information from GSA? The invoicing requirements for most GSA Schedule contracts can be found under Contract Clause 52.212-4 (Contract Terms and Conditions - Commercial Items).
Responding to Option Extensions
Every 5 years (and for up to 20), you will have the option to extend your GSA Schedule provided you are maintaining compliance and meeting the minimum sales requirement.. GSA will evaluate whether you have been meeting your terms and conditions and keeping up with your contract maintenance. Expect to file multiple modifications to prepare and keep in mind that GSA will want to renegotiate your contract.
Sales Reporting
If you are subject to Transactional Data Reporting (TDR), you will need to report your sales monthly. For Non-TDR (if you opt into CSP) contractors, you will need to report your sales quarterly at the end of a month following a quarter. For example, if the quarter ends in March, you’ll need to report the sales by April 30. New quarters start on January 1, April 1, July 1, and October 1.
Every quarter (or you can opt to pay monthly if using TDR), you will also need to remit your Industrial Funding Fee (IFF) which is 0.75% of your GSA sales.
Subcontracting Reporting
If you have a small business subcontracting plan, you will need to report it on a regular basis. If you have a commercial plan you will need to fill out a Summary Subcontracting Report (SSR) annually on October 30. If you have an Individual Plan, you will need to submit a SSR and an Individual Subcontracting Report (ISR). ISRs are due April 30 and October 30.
Meeting the Minimum Sales Requirement
The GSA minimum sales requirement was changed recently. GSA revised clause I-FSS-639 to change the time period to 5 years, which is the same timeframe as each GSA Schedule option period.
In this timeframe, contractors will need to make $100,000 for the first 60 months (5 years) of the contract, and $125,000 for each 60 month period thereafter. This change is anticipated to take place before the end of December 2024.
VETS 4212
Your Veteran’s affirmative action is due annually on September 30.
EEO-1 Survey
Your Race/Ethnicity and Gender affirmative action reporting is due May 30.
Be Sure to Stay On Top of Your Contract Maintenance and GSA Updates
Although the list above is extensive, not all requirements are absolute for every vendor. The nuances of your individual company, along with the terms and conditions that were awarded to your GSA Schedule, will determine your obligations as a contractor.
We encourage you to join GSA Interact for frequent updates and attend as many GSA webinars and events as you can so you are well aware of what is going on in the world of GSA.
From the GSA Events page, I would highly recommend registering for GSA’s MAS Office Hours meetings. In these meetings, different topics are discussed each month and it will give you an opportunity to engage with GSA staff, policy makers, and other federal contractors.
As consultants, we provide clarity in a very convoluted process. If you are interested in conserving your level of effort to maintain your GSA contract and hiring a consultant to help you keep track of your contract and maintain compliance, then one of Winvale’s GSA experts would be happy to help you.
