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Managing your GSA Multiple Award Schedule (MAS) contract is not an easy task. There are many items to keep up with, which require organization, knowledge, and most of all, time. A large part of maintaining your GSA Schedule is making sure your contract is updated through various compliance requirements. With the Trump Administration looking for ways to cut costs and increase efficiency, they are cracking down on contracts that aren't compliant. In this blog, we will highlight the top 10 most forgotten updates that contractors miss when managing their GSA Schedule contract. Read further to avoid skipping over any important compliance and to be well prepared for your next Contractor Assessment Visit (CAV).
1. SAM.gov Registration Renewal
Companies are required to keep an up-to-date Systems for Award Management (SAM) registration if they are doing business with the federal government. This registration lasts for a year and companies often forget to renew their registration in time. SAM is often backed-up with requests, especially as the federal government recovers from the shutdown. so it could take longer than you think to process and complete your renewal. You'll want to leave extra time in case you have issues with your entity validation or run into any other snags.
To make sure your SAM registration is up-to-date, you can go to the portal on SAM.gov and see when your registration ends. We suggest if your company has a lot of changes to monitor and update this site at least twice a year instead of annually. Be careful if any company reaches out to you regarding your SAM.gov registration—SAM.gov is always free to use and update. There have been many companies trying to scam contractors into paying for a “registration service fee” while pretending to be affiliated with SAM.gov. If you wait until the last minute to register, some of these scammers will capitalize on your sense of urgency and send emails promising an immediate renewal for a price.
2. Submitting a Modification On Time
Whenever a company needs to modify their GSA contract, whether it's change of address, adding a new product, or updating pricing, they must submit a formal modification via eMod for approval. GSA has recently begun transitioning all contractors from the Schedule Input Program (SIP) to the FAS Catalog Platform (FCP). When you submit a modification in eMod, it'll prompt you to upload the appropriate documentation into the FCP, making the process more efficient.
While the process is more efficient, contractors still need to remember to stay on top of their modifications and submit them on time. If you are looking to adjust product or service information for an upcoming opportunity, or have a new product you want to be visible on GSA Advantage!, you should submit your modification sooner rather than later. As GSA prepares to expand procurement, they may be a bit short staffed and have slower modification approval times.
3. Preparing for Option Extensions
You can have your GSA Schedule for up to 20 years, but the contract is broken down into 4, 5-year periods. This means, every 5 years you will need to complete an option extension if you want to continue your contract. Your contract will not automatically be renewed. You'll need to make sure you are meeting all the applicable compliance requirements, and document if there are any changes to your terms and conditions. GSA will conduct a contract review to ensure your Schedule is following all the requirements. While GSA will remind you it's time to start preparing for an option extension, many contractors wait until the last minute and are scrambling to gather all the necessary evidence.
4. Mass Modifications
GSA performs updates to the MAS Solicitation every time there is a significant change, such as the recent Solicitation Refresh #30. These are called mass modifications. Companies frequently neglect these mass modifications, leaving their contracts outdated and out of compliance.
For every mass modification, you must go to the Mass Mod Portal and accept it within 90 days of the release in order to keep the terms and conditions of your GSA contract up-to-date. Even if it seems like the updates within the Solicitation Refresh don't apply to you, it must be done by all contractors. Contractors should also note that the Mass Mod portal has switched over to a Multi-Factor Authentication log-in in the past few years, so make sure your GSA FAS ID is current.
5. Updating Your GSA Schedule Terms and Conditions
While the FCP streamlines and automates a significant portion of your catalog management, you need to pay close attention to your Schedule's Terms and Conditions. The FCP system automatically generates and publishes a formatted pricelist to GSA Advantage!, GSA eLibrary, and GSA eBuy based on the data entered into the Services Plus or Product File when you submit a modification. However, the Terms and Conditions File is a separate FCP that needs to be updated as well if your modification affects contractual terms.
This is an area many contractors may overlook. If your delivery timelines, warranty language, or service delivery methods etc. have changed since your last modification, your GSA-approved Terms and Conditions need to be updated. Even with FCP in place, it’s still important to periodically review your T&Cs to ensure they accurately reflect your catalog.
6. Sales Reporting
One of the main requirements in maintaining your GSA contract is your sales reporting. This report is submitted through the FAS Sales Reporting Portal (FAS SRP) in order to have a record for every contractor’s sales. If you are currently under Commercial Sales Practices (CSP), you'll need to submit quarterly, and if you're under Transactional Data Reporting (TDR), you'll need to submit monthly. GSA recently expanded the scope of TDR to several more Special Item Numbers (SINs), so we expect all contractors to eventually be transitioned to TDR. Regardless of your reporting type, you must also remit the Industrial Funding Fee (IFF) every quarter (or every month if you so choose).
7. Listing Your GSA Contract Number On GSA Quotes
This is a small compliance measure, but still important. More times than not, vendors fail to remember to list their GSA contract number on GSA sales quotes. Listing your GSA contract number on all GSA sales quotes is required because it allows the purchaser to be able to reference your contract to make sure they are getting the correct price. It also helps you determine what is a GSA sale and what is not when you're prepping for sales reporting and IFF payment.
8. Prompt Payment Discounts
Also required on your invoices is a statement referencing your Prompt Payment Discount for companies who pay the invoice before the net 30 days. If your company fails to do this, it can result in overcharging and if the purchaser recognizes this mistake, you may need to go back through your records and reimburse them for the losses they endured. This is why it is crucial to list your Prompt Payment Discount on your invoices so you can keep your customers well informed.
9. Ongoing Trade Agreements Act (TAA) Compliance
Many contractors think once they get their GSA Schedule contract that Trade Agreements Act (TAA) compliance is set for the entirety of their contract, but they need to pay attention to it more often. If your supply chain shifts, such as a manufacturer moves production and you switch distributors, or you have a new product, you are responsible for ensuring every item listed on your Schedule is still TAA-compliant.
This is why contractors need an internal system or workflow to verify country-of-origin (COO) changes and manufacturer updates before submitting modifications through the FCP. A product that was compliant at award may later become non-compliant if production moves to a restricted country, and outdated COO records are a common issue discovered in CAVs.
10. Prepping for Contractor Assessment Visits
Contractor Assessment Visits (CAVs) happen at the mid-point of your 5-year GSA contract period and about 7-12 months before your contract expires. Many contractors view them as audits, but they exist to help make sure companies have efficient internal controls in place to maintain compliance.
The best way to prepare is to gather all the documentation your Industrial Operation Analyst (IOA) requests ahead of the meeting, and make sure you are abiding by all the compliance requirements for your GSA Schedule.
Do You Need Help Keeping Up with Your GSA Schedule?
GSA compliance can be a lot of work, but it’s important to keep your contract current and accurate to make the best use of it. If you want to learn more about ways to keep your contract maintained properly, check out our blogs, “How to Maintain Your GSA Schedule Contract: An Essential Checklist” and "The Importance of GSA Schedule Compliance."
We also understand that following these tasks as well as running your commercial side of the business can be overwhelming and time consuming to say the least. If you need a little (or a lot) of help managing your GSA Schedule, we would be happy to help you.
