Since taking office, President Trump has signed multiple Executive Orders (EOs) impacting federal procurement and the operations of popular contract vehicles. For example, a recent EO was signed to consolidate many Governmentwide Acquisition Contracts (GWACs) under GSA, due to the agency’s expertise in managing federal procurement through the Multiple Award Schedule (MAS) and other contracts.
While most affected agencies are still in the planning phase for this transition, current contractors should engage in key GSA Schedule management activities now to ensure your contract is prepared for this anticipated increase in federal sales opportunities. In this blog, we will discuss recent EOs, tips for contract compliance, and GSA Schedule business development resources.
Recapping Recent Executive Orders and Policies Impacting GSA
As mentioned, President Trump’s EO aimed to consolidate domestic federal procurement under GSA specified that federal agencies will need to submit a proposal within 60 days of the EO for steps to transition their current procurement processes to GSA. This action is related to President Trump’s January EO establishing the Department of Government Efficiency (DOGE) to increase efficiency in government operations.
Subsequently, GSA began an effort to “rightsize” the MAS program, which includes cancelling GSA Schedule contracts that are not compliant with Solicitation requirements, such as not meeting the $100,000 minimum sales requirement for your base period or $125,000 for each exercised option period.
Recently, another EO was signed directing the Administrator of the Office of Federal Public Procurement Policy (OFPP) and other Federal Acquisition Regulation (FAR) stakeholders to create “FAR 2.0” within 180 days, which is aimed to eliminate FAR clauses that are considered unnecessary to guide federal procurement processes.
Considering these current EOs and the Administration’s efforts to increase the efficiency of government operations through DOGE, it’s important for contractors to identify GSA Schedule management activities that need to be addressed to ensure they are remaining compliant with the recent changes in the federal government, which we will discuss next.
How to Maintain a Compliant Schedule
To participate in GSA Schedule business development opportunities and increase your sales, you will need to have a contract that remains in compliance with recent EOs and subsequent changes in GSA by following the GSA Schedule management tips below.
Contractor-Initiated Modifications
GSA allows contractors to propose changes to their awarded offerings and terms and conditions associated with their contract by submitting contract modifications through the eOffer/eMod portal. With an increase in federal procurement through GSA and the MAS expected, it may be beneficial to begin adding any products or services you have been developing to your contract to fulfill buyers’ requirements who will now be looking to source through GSA MAS.
You can modify your contract in multiple ways, including adding products or labor categories to your already awarded Special Item Numbers (SINs), adding products under a new SIN, or leveraging recent project experience to add new service-based SINs to expand your company’s access to task order opportunities.
Similarly, you will want to make sure your GSA prices are up to date. The mechanism to increase your GSA rates depends on your awarded Economic Price Adjustment (EPA) clause. Through a deletion modification, you can remove any obsolete products or services from your awarded offerings to reduce any task order complications.
GSA Schedule contractors should also make any necessary administrative modifications to ensure you are representing your business accurately to federal buyers each year and are meeting compliance requirements, such as listing your correct business size, address, and order Point of Contact (POC) information.
Mass Modifications
Periodically, GSA will update the MAS Solicitation to revise certain clauses, instructions, or requirements for SINs and the proposal development process, among other changes. Since January, there have been two “refreshes” of the MAS Solicitation that contractors are required to review and accept through the Mass Modification system within 90 days, which have featured direct impacts from recent EOs.
For example, GSA has already released an Solicitation Refresh #26, which includes the removal of 32 SINs from the available offerings contractors can have awarded; this feature of the upcoming mass modification can be linked to the new Administration’s efficiency goals and should remove the administrative burden of underperforming SINs from GSA staff to other procurement methods. Thus, you should identify if any of your SINs will be retired and contact your assigned Contracting Officer or Contract Specialist for guidance if your only awarded SIN will be removed.
Sales Reporting
GSA has become more stringent about letting contracts expire that do not meet the minimum sales criteria for each option period or do not at least make a significant effort to meet these minimums. Thus, contractors’ GSA Schedule management practices for sales reporting have become more important than ever.
Contractors should be reporting their GSA sales in the Federal Acquisition Service (FAS) Sales Reporting Portal (SRP), either monthly or quarterly depending on whether your contract was awarded under Transactional Data Reporting (TDR) or Commercial Sales Practices (CSP). While it may seem easy to differentiate between a GSA and commercial sale, contractors can miss report a GSA sale in the SRP, especially if they had been busy commercially during a specific month or quarter. Consequently, contractors should set up their internal sales tracking systems effectively to report the correct data to GSA and pay the corresponding Industrial Funding Fee (IFF).
GSA Schedule Business Development Opportunities
Now that you are aware of the tools available for effective GSA Schedule management and compliance practices, let’s discuss how to grow your contract in the changing federal marketplace. There are many resources available to research GSA Schedule business development opportunities, such as Schedule Sales Query Plus (SSQ+), USAspending.gov, and paid forecasting services.
SSQ+
This tool allows you to analyze raw sales data for each SIN and competitors’ yearly sales data. While SSQ+ does not provide details on specific contract awards, it’s a good starting point to understand successful SINs and competitors. You can also visit GSA Advantage! or GSA eLibrary to investigate which SINs, products, and services your competitors have been awarded to identify if you are missing out on any opportunities in your own GSA Schedule offerings.
USAspending.gov
If you want to research agencies’ recent spending habits, then visit USAspending.gov. This site allows you to filter award data by funding or awarding agencies, NAICS Codes, recipients, and more, to see how agencies are using their allocated funds, which can help you target potential federal buyers with your services or products.
Subscription-Based Tools
There are paid forecasting services that allow you to gain insight into upcoming opportunities that are expected to be released through GSA MAS, such as GovWin. These tools can help you prepare your GSA Schedule for any required SINs, products, or services you may need to add to your contract to be ready to respond.
Is Your GSA Schedule Prepared for GSA’s Expansion?
It can be difficult to stay up to date on each EO released, knowing how these policy changes impact GSA MAS, and how to coordinate your company’s GSA Schedule management strategies accordingly. By following our blog, you can stay informed on the Administration’s new policy changes that impact federal procurement and resources available for GSA Schedule business development activities.
If you are reading this post based on GSA’s anticipated expansion and large-scale procurement responsibilities, you may be interested in acquiring a GSA Schedule contract. Our consultants are available to advise your business on the best practices for navigating offer requirements, complex compliance issues, and the impact recent EOs will have on the federal marketplace.
