While the GSA Multiple Award Schedule (MAS) acquisition process can be a long and drawn out process, the work doesn’t end once your Schedule has been awarded. GSA Schedules have a potential life span of 20 years (four 5-year option periods), so it’s rare that a contractor’s GSA Schedule offerings, Special Item Number (SIN) selections, administrative information, etc. remains the same throughout the life of the contract. GSA Schedule contract holders can update or change essentially every part of their contract throughout its existence through a modification. In this blog, we will discuss the types of modifications, and why they are an integral part of GSA Schedule compliance.
Why Should You Modify Your GSA Schedule Contract?
As previously mentioned, once contractors are awarded a GSA Schedule contract, it can last up to 20 years. Throughout the life of your GSA Schedule, you will need to make several updates to reflect changes with GSA, your offerings, and company. These contract updates can range anywhere from changing administrative information such as an address or phone number, to updating pricing information or adding/removing products and services from the Schedule.
Not only is it important to have knowledge of modifications and how to apply them from a contract compliance perspective, but it’s also a necessity from a business development standpoint.
To make contract changes, GSA requires that you utilize their electronic contract modification submission system, eMod. eMod is a secure interactive web tool that allows vendors to prepare and submit their GSA Schedule contract modification requests online, simplifying the overall contract process.
Types of GSA Schedule Modifications
The 10 main contract modification types are:
- Administrative
- Addition of Products/Services or SIN
- Deletion of Products/Services or SIN
- Economic Price Adjustment (EPA)
- Price Reduction
- Technical
- Terms and Conditions
- Legal
- Cancellation/Terminations
- Mass Modification
Now let’s dive into each one of them to explain their purpose for your GSA Schedule.
1. Administrative Modifications
Administrative modifications are used when contractors need to make organizational updates. The following are common administrative mods:
- Address Change
- Contract Administrator/Point of Contact (POC) or Authorized Negotiator Change
- Email Address Change
- Fax Change
- Industrial Funding Fee (POC) Change
- Points of Contract (POCs) for manufacturers, dealers, resellers, agents changes
- Order Point of Contact (POC) change
- Website address change
One unique aspect of these mods is you can combine multiple administrative changes into a single modification. For example, you can submit one mod for a change in authorized negotiator, phone number, and email address. This can’t be done with any other mod types. For changes to address or website address, you would need to make the change in SAM.gov before it could be updated in eMod.
2. Addition Modification
An Addition modification covers a larger range of possible items that can be added, including additional SINS, new models, new brands, products and/or services. Contractors will typically use an Addition Modification to seek a new opportunity within their GSA Schedule.
It’s important to note that contractors cannot add any new products or services to their GSA Schedule that they have not first sold commercially. Contractors will be required to provide pricing support examples (invoices, quotes, contract examples) and Past Project Narratives to illustrate this point.
3. Deletion Modification
Like an Addition modification in which a contractor is adding products or services to their GSA Schedule, a Deletion modification would occur when a contractor wants to remove products/services from their GSA Schedule.
A contractor may choose to execute this modification when they are no longer selling those products/services in the commercial space and therefore want to remove them from their GSA Schedule. Deletion modifications are considered RAM’s (Rapid Action Modifications) and are usually processed much quicker on the GSA side since there is less documentation to review.
4. Economic Price Adjustment (EPA) Modification
An Economic Price Adjustment (EPA) modification is used by contractors when they would like to increase the price of a product or service on their GSA Schedule. This may come about when contractors realize their GSA prices are no longer proportionally equivalent to their commercial prices.
Like an Addition modification, contractors must be able to show evidence that their commercial prices have increased before they are able to request a price increase to their GSA prices through an Economic Price Adjustment mod. Contractors should first confirm which EPA clause is awarded to their GSA contract before proceeding with an Economic Price Adjustment (EPA) mod to ensure the modification is submitted properly and does not get rejected.
It’s important to note that GSA plans to consolidate all the EPA clauses into one, but a formal change hasn’t been made yet to the MAS Solicitation.
5. Price Reduction Modification
A Price Reduction modification may sound like a modification that would be counterproductive for a contractor, but they are occasionally required to be used. Contractors who use Economic Price Adjustment Clause I-FSS-969 are required to decrease their GSA prices if their commercial prices are also decreased, so that they are not in breach of the Price Reductions Clause.
For instance, if a contractor decreased commercial prices by 2%, then the contractor would be required to decrease their GSA prices by 2% to maintain the same discount delta.
6. Technical Modification
Technical modifications are minor changes that need to be made to a product or service without changing its price or the solution itself. Examples of Technical mods include:
- Part Number Change
- Product Description Changes
- Service Description Changes (education, work, experience)
You can use Technical mods to your advantage. For example, based on the item you are selling, you could alter your description to include keywords or buzzwords so government agencies will find you easier. Especially now that we have a new administration, it could be worth going through your product/service descriptions to see if there’s a place to edit the language to better fit the current administration’s mission and goals.
7. Terms and Conditions Modification
Terms and Conditions modifications include changing your business from Small Business to Other Than Small Business (OTSB), incorporating a subcontracting plan, and changing delivery time. You can also choose to sign-up for Cooperative Purchasing and Disaster Purchasing in this mod (as long as your SIN is eligible), two options to sell to state and local government through the GSA Schedule.
8. Legal Modification
Legal modification options in eMod include two specific modification types: Change of Name Agreements and Novation Agreements. A Change of Name Agreement Modification occurs when a company has changed their name legally, and that change needs to be reflected through GSA. A Novation Agreement modification occurs when a new party agrees to take over a government contract from the original contractor. Novation Agreement are necessary when a company is purchased by another company and their assets are transferred.
9. Cancellation Modification
The Cancellation modification is exactly what it sounds like –if you want to cancel your GSA Schedule contract in part or in whole, you will submit this mod. A Cancellation mod goes into effect 30 days after signature and contracts can't be reinstated after this date.
10. Mass Modifications
A Mass Modification is different from a traditional contractor-initiated modification in that it is initiated by GSA. Mass Modifications are typically all-encompassing updates that incorporate new government regulations or legislation and require the contractor’s acceptance. Typically, GSA will try to limit Mass Modifications to once every two months, but this varies. Contractors will receive a notification from their contracting officer once a new Mass Mod is released, and will be instructed to log into the GSA Vendor Support Center Mass Mod Portal and accept the Mass Mod. As of this date, the most recent Mass Modification GSA released was MAS Refresh #24 Mass Modification A888.
Using the Multiple Award Schedule Modification Guide
If you ever find yourself looking for additional modification information, the Multiple Award Schedule (MAS) Modification Guide is a great tool to reference. Here, GSA provides a detailed breakdown of modification types and the accompanying documentation that is needed for each modification type.
Having the knowledge of these modification types will help contractors be more successful in utilizing their GSA Schedule to its full potential. Do you have more questions about modifications and their uses? Winvale is here to help!
