Contract compliance should always be a priority for Multiple Award Schedule (MAS) contractors, but it’s now more important than ever. The new administration has recently issued Executive Orders and initiatives aimed at increasing both government efficiency and taxpayer savings. As a result of these federal policies, GSA is enforcing contract compliance more heavily, with the goal of increasing the MAS program’s efficiency.
For MAS contractors, this means that even small instances of noncompliance, such as being unresponsive to GSA’s emails, could lead to contract cancellation. It’s worth noting that since GSA relaxed its enforcement of contract compliance during the pandemic, this heightened enforcement may seem even more pronounced.
Given all this, it’s crucial to be aware of what GSA Schedule compliance entails. In this blog, we’ll cover the key areas of contract compliance that Schedule holders should be paying attention to in order to remain in good standing and avoid contract cancellation.
Meeting the Minimum Sales Requirement
While the Multiple Award Schedule’s Minimum Sales Requirement has always been around, the Trump administration’s new Department of Government Efficiency (DOGE) has been pushing GSA to enforce it more strongly. Contractors that don’t meet the Minimum Sales Requirement in their five-year base period may face contract cancellation when attempting to extend their contract for the next five-year option period.
To meet the Minimum Sales Requirement, contractors must make $100,000 for the first 60 months (5 years) of the contract, and $125,000 for each 60-month period thereafter. GSA changed this requirement in 2024 to give contractors more time to drum up business and to align the sales requirement periods with the 60-month contract option periods. Previously, contractors were required to make $25,000 in GSA Schedule sales within the first 2 years of their contract, and $25,000 every year thereafter.
These sales minimums are fairly attainable if your company has done work with the government before. However, if your company is new to government contracting, they may seem daunting. We recommend honing your GSA marketing strategies to have the best chance at meeting these sales minimums.
Reporting Sales on Time and Correctly
Sales reporting is another important aspect of GSA contract compliance. GSA contractors have different sales reporting requirements depending on their contract type. Contractors who are subject to Commercial Sales Practices (CSP) must report their GSA sales quarterly, while contractors subject to Transactional Data Reporting (TDR) must report their GSA sales monthly. Keep in mind that sales reporting is required even for periods when you’re reporting $0 in sales.
Reporting deadlines fall on the 30th of each month for TDR contractors, and on the 30th of the month following a sales quarter for CSP contractors (e.g. April 30th for the quarter ending in March). Setting recurring calendar reminders is helpful for keeping track of sales reporting deadlines.
All contractors report their sales through the FAS Sales Reporting Portal (SRP). Reporting sales correctly starts with correctly determining which of your recent sales are considered “GSA sales” – for example, open market sales are not considered GSA sales.
Next, make sure that you’re reporting all of the information required for your contract type. While CSP contractors report their total sales per Special Item Number (SIN), TDR contractors report on 11 different fields for each order. Accurate, complete reporting is important for maintaining compliance and avoiding contract cancellation.
Remitting the Industrial Funding Fee (IFF)
To remain in good standing as a GSA contractor, you’re also required to remit the Industrial Funding Fee (IFF). The IFF is 0.75% of each GSA sale and is used to fund GSA’s operating costs. Both TDR and CSP contractors need to pay the IFF quarterly, on the same day that CSP reporting is due (January 30, April 30, July 30, October 30). Since the IFF is paid using the SRP, TDR contractors may find it easier to pay their IFF monthly, since they already need to log in to the SRP monthly to report sales.
The IFF should only be remitted for items that are considered GSA sales. Correctly identifying your GSA sales will ensure that you avoid overpaying the IFF.
Keeping Pricing Updated
Updating your pricing is crucial to maintaining contract compliance. The prices on your GSA Schedule represent ceiling prices, so if you’d like to increase prices – for example, due to recent tariffs increasing raw material costs – then you’d need to submit an Economic Price Adjustment (EPA) modification. Charging GSA customers above your approved GSA prices will lead to issues at your annual assessment, so make sure to keep up with EPA modifications.
If you’re a contractor subject to Commercial Sales Practices, keeping your pricing updated and compliant with the Price Reductions Clause is also important for avoiding contract cancellation. Per the Price Reductions Clause, you have 15 calendar days to notify your Contracting Officer anytime the discount delta between your Basis of Award pricing and your GSA pricing changes. You’d then need to reduce your GSA prices to restore the original discount delta, or else you could risk having your contract cancelled.
Compliance aside, regularly reviewing and updating your pricing to remain competitive in your market is always a good idea. We also recommend taking a look at the new administration’s priorities when strategizing your pricing.
Making Sure You’re Responsive
In addition to being a good business practice, responsiveness to GSA’s email communications has become an additional metric for contract compliance. Contractors who aren’t regularly monitoring their inbox for email inquiries from GSA and responding in a timely manner could risk having their contract cancelled. This is especially true for emails regarding something as important as a Contractor Assessment Visit (CAV).
That said, you can avoid potential contract cancellation by making sure you have the right individuals assigned to your GSA contract roles, since they’ll be receiving GSA’s email communications. Each contract role plays an important part in contract compliance, as summarized below:
- The Order POC monitors the Purchase Order (PO) portal for orders
- The IFF POC pays the IFF each quarter in the Sales Reporting Portal
- The Contract Administrator manages overall contract administration and is listed on GSA eLibrary
- Authorized Negotiators are authorized to make contract changes and updates
To ensure that GSA can reach these individuals, you’ll want to confirm that their contact information is up to date in GSA’s eOffer/eMod system. If you need to update their contact information or the individuals themselves, you can do so through a quick administrative modification. Keep in mind that while you can have the same person fill all these roles, it’s a good idea to use a team if possible, to have another pair of eyes on GSA-related emails.
Starting Streamlined Offers Early
While this topic goes a bit beyond traditional contract compliance, read on if you’re a current GSA contractor with fewer than five years left in your contract’s 20-year lifespan. In order to renew your GSA contract past its 20 years, you’ll need to go through the streamlined acquisition process, which is essentially a simplified version of the Schedule acquisition process for new offerors.
If you’ve maintained compliance as a Schedule holder and met the minimum sales requirements, the streamlined acquisition process shouldn’t be too onerous. However, we want to call your attention to the latest guidance regarding when you should start preparing your streamlined offer.
In the wake of the Trump Administration’s Executive Order expanding procurement under GSA, GSA is going through a period of transition, resulting in longer review times and the need to start streamlined acquisitions earlier. GSA now recommends that existing MAS contractors begin their streamlined acquisition process at least 24 to 36 months from the date of their current contract’s expiration, to ensure there isn’t a gap between the existing and new contracts.
With all these changes at GSA, contractors may have their streamlined offer evaluated by a different Contracting Officer from the one currently assigned to their contract. Therefore, in addition to starting the process early, it’s important to put together an airtight streamlined acquisition offer that can pass muster with any Contracting Officer.
Other Requirements for GSA Contractors
The elements of contract compliance that we’ve discussed are critical for remaining in good standing as a MAS contractor and avoiding contract cancellation. However, these elements are only a starting point when it comes to GSA contract requirements.
From accepting mass modifications to renewing your SAM registration, the maintenance requirements for Schedule holders can stack up. Our essential maintenance checklist provides a comprehensive overview of maintenance obligations for GSA contractors. If you have further questions or are interested in outsourcing your GSA Schedule maintenance responsibilities, our consultants are here to help.
