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With the new administration cracking down on non-compliant GSA MAS Schedule contracts, it’s important to understand how Contractor Assessment Visits (CAVs) work and how to succeed. No contractor wants to be caught off guard when conducting business with their GSA MAS contract, so it’s crucial to remain compliant and avoid putting your contract in danger.
In this blog, we’ll discuss what a Contractor Assessment Visit (CAV) is, the difference between Annual Assessments and End of Term (EOT) Assessments, what your Industrial Operations Analyst (IOA) looks for during the Contractor Assessment, and how to prepare for a Contractor Assessment Visit.
What is a Contractor Assessment Visit (CAV)
A Contractor Assessment Visit (CAV) is a review of your records to verify contractual compliance. A CAV can occur within three years of your contract’s expiration date, and it is not an audit. The frequency of assessments is sporadic, and an Industrial Operations Analyst (IOA) will conduct the assessment. As stated in contract clause 552.238-83 Examination of Records by GSA, IOA’s can assess compliance in areas such as sales reporting, scope of contract, pricing, basis of award (BOA) and more. The assessment process can take a few hours overall and may not be consecutive.
Annual Assessments vs End of Term Assessments (EOT)
There are two types of CAVs: Annual Assessments and End of Term (EOT) Assessments. Assessments are conducted either in-person or virtually, depending on your IOA’s proximity to your location. Annual assessments are conducted up to once per year, and EOT assessments occur during the fourth year of each five-year contract period. They also differ in the compliance topics they cover:
Key Questions Your Industrial Operations Analyst (IOA) May Ask During a Contractor Assessment
Contractor Assessment Visits (CAVs) may uncover issues within the compliance of your GSA MAS Schedule contract, so it’s important to know what IOA’s are looking for and how to avoid problems during your assessment. This is not an exhaustive list, but below are some examples of questions IOAs ask themselves while conducting a Contractor Assessment:
1. Do you have a system in place to accurately and timely identify, track, and report your GSA contract sales?After being awarded your GSA MAS contract, it’s important to have a system that captures accurate and complete GSA sales. Contractors often under-report sales because they only report sales from GSA Advantage or eBuy. GSA accepts any method of sales tracking that is complete and accurate. Some contractors think under-reporting is the only issue, but over-reporting is also a problem.
2. Are your GSA contract customers being charged the approved GSA contract price (or lower)?Price changes can only be made through an Economic Price Adjustment (EPA) modification, and your price list should reflect the prices that have been approved by your Procurement Contracting Officer (PCO). Your IOA will review orders placed under your contract and compare them to your approved pricelist. If your IOA determines you have overcharged customers, you will be required to pay back the difference.
3. Are the products/services that you are selling as being on your GSA contract, actually on your GSA contract?All products and services on your GSA MAS Schedule contract must reflect the Special Item Numbers (SINs) awarded to your contract. Your IOA will review offers, quotes, purchase orders, and other documentation to confirm that the products and/or services you are selling comply with the SIN(s) you have been awarded. As a GSA MAS contractor, you are responsible for making sure your products and/or services align with the scope of your contract.
4. Are you delivering your GSA contract orders/projects on time?Delivery times for your products and/or services must be consistent with the terms of your contract, whether that is a default delivery time or negotiated per order. Your IOA will review purchase orders, shipment, and delivery documentation for all orders under your contract. For services, your IOA will want to see project reports or your delivery terms negotiated with your customer.
How to Prepare for your Contractor Assessment Visit (CAV)
Before your CAV, your Industrial Operations Analyst (IOA) will provide a list of all documentation needed to conduct the Contractor Assessment. Your IOA will typically request 12 months of data for every GSA MAS transaction during the specified time period, along with details related to your processes for tracking compliance with the Trade Agreements Act (TAA), pricing, staff training, and more. Failing or refusing to facilitate an assessment could result your contract terminated, so it’s best to provide all requested documentation. GSA’s Multiple Award Schedule Contractor Assessment Reference Guide is a great resource for more in-depth information about what documentation you should have ready for your assessment.
Are You Prepared for Your Contractor Assessment Visit (CAV)?
Contractor Assessment Visits (CAVs) can be daunting, but the process is less stressful if you know what to expect for you and your company. The best way to prepare for a CAV is to have organizational processes and procedures in place soon after your contract is awarded so you’re able to have a manage your compliance documents.
If it is difficult for your company to maintain organization with compliance documents and procedures, Winvale is here to help!
