One large source of confusion for GSA contractors can be determining the Country of Origin for offered products. Many people think all GSA awarded items must be made in the USA, but this is not the case. Instead, all products offered on a GSA schedule must be produced in a country that is compliant with the US Trade Agreements Act (TAA). Many countries are TAA-compliant, but one major manufacturing course is not – you probably guessed it, CHINA. This means GSA cannot award any items that are manufactured in China onto your GSA contract. Some contractors have trouble determining the exact Country of Origin, as different components come from different countries or different manufacturing processes are performed in different countries. In cases like this, merchandise originates from the country where it has been substantially transformed into a new and different article of commerce with a name, character, or use distinct from that of the article or articles from which it was transformed. For this language, please see the Federal Acquisition Regulations 52.225-5 for more detail: https://www.acquisition.gov/far/05-10r/html/52_223_226.html#wp1169151

On November 2nd, the U.S. General Services Administration in coordination with the Federal Chief Information Officers Council released comprehensive requirements for the Federal Risk and Authorization Management Program, or FedRAMP, for public comment. This is a huge milestone in the governmentwide adoption of cloud computing services. The security authorizations and continuous monitoring of cloud systems that FedRAMP will provide can be used by agencies to streamline their security process while still providing highly effective security services. FedRamp allows agencies to make use of commonly accepted risk assessment and cyber security evaluation of cloud services. Joint authorizations of cloud providers will result in a common security risk model that can be leveraged across the federal government, ensuring a consistent baseline for cloud-based technologies.

One of the most common questions we get on a day to day basis has to be: "how soon will we have our Schedule in place?" The party line from GSA is that it takes a Contracting Officer, on average, 120 days to review, clarify, negotiate, and award a GSA contract. However, for many GSA Schedules and contractors, this is not always the case. What distinguishes a proposal that undergoes an "extended" review versus one that follows the traditional timeframe? It has everything to do with submitting a proposal that is fully responsive to a schedule solicitation, right? ....Well, not necessarily.

GSA, the federal agency in charge of establishing per diem rates for federal travel, has released the reimbursement rates for fiscal year 2011, effective October 1st. Per Diem is essentially an allowance for daily expenses that are reset each fiscal year beginning on October 1. The federal per diem rate can be raised or lowered by a Per Diem Committee that surveys local meals and lodging rates. This committee uses local industry standards to ensure that taxpayer dollars aren't being misspent.

Once you have an awarded GSA Schedule Contract, it is important to keep records and ensure compliance with the terms of your contract. Twice during your five year GSA contract term, you'll have a Contractor Assistant Visit (CAV). Some people think of the CAV as an audit, but the purpose is really to make introductions, assess your performance, check records, and identify any problem areas. If there are any serious concerns that exist after the CAV, your Contracting Officer will give you the opportunity to correct these issues.

Any large business receiving a GSA contract, where they expect GSA sales to exceed $650,000, must agree that small business, veteran-owned small business, service-disabled veteran-owned small business, HUBZone small business, small disadvantaged business, and women-owned small business concerns will have the maximum practicable opportunity to participate in contract performance consistent with its efficient performance. Recently GSA has required Small Business Subcontracting plans from all large businesses, regardless of anticipated GSA sales and many contractors struggle to understand this policy and fulfill the requirements. Make no mistake, small business subcontracting is considered a "deliverable" under the contract and should be taken seriously.