While securing a Multiple Award Schedule (MAS) contract from the General Services Administration (GSA) may appear to be the most demanding element of the procedure, maintaining contract compliance can be even more challenging. For one, every contractor gets obligated to disclose their GSA sales every quarter once the contract gets awarded.
Moreover, contractors must pay the associated Industrial Funding Fees (IFF) while reporting their GSA sales. You must correctly identify contract sales and distinguish them from other non-contract sales, both governmental and non-governmental.
With that, this article will discuss what counts as a GSA sale and how to determine if a sale is reportable under a GSA MAS contract.
What Qualifies a GSA Sale?
Here are the GSA Vendor Support Center’s instructions for assessing whether a transaction is reportable:
- If you sell a contract item to an authorized user at contract prices (or lower).
- There is no indication of another contract vehicle in place.
If one or more of these checklist items are present while reviewing a sale, this sale is likely reportable under your MAS contract:
- Your GSA contract includes the product or service.
- The price is equal to or less than the MAS pricing.
- GSA Advantage! or eBuy is used to contact the customer.
- Your ordering information and terms are consistent with your contract.
- The GSA contract number is listed.
- A government-issued commercial purchase card gets used to pay.
- There is no other procurement vehicle used in acquiring goods or services.
What Does Not Qualify as a GSA Sale?
It is critical to remember that open market item sales do not get counted as GSA sales under your MAS contract.
No contract gets awarded for open market items. However, you can use them to fulfill the requirements of a contract; nevertheless, you must explicitly mark them as such. Moreover, except for particular and unusual circumstances that come under Federal Acquisition Regulation (FAR) 51.1, you would not be permitted to record those GSA sales if you worked as a subcontractor.
How to Find Out if a GSA Schedule Sale Is a Reportable Transaction
Understanding whether the GSA Schedule contract covers a transaction is one of the most often asked questions about sales. A transaction may be classified as a GSA Schedule sale if one or more of the following factors get met:
- The product or service is on your GSA contract.
- The GSA contract number gets stated on the purchase or task order.
- Your ordering information and terms are consistent with your contract.
- GSA Advantage! or eBuy is used to contact the customer.
- The price is equal to or less than the MAS pricing.
- There is no other procurement vehicle used in acquiring goods or services.
- You used a Letter of Authorization using FAR 51 or a FAR 51 Deviation to sell to a private company.
- You must include the Industrial Funding Fee (IFF) in the items given under the Order-Level Materials (OLD) SIN.
GSA recognizes a sale that gets recorded following your established commercial accounting procedures. You may decide to report a GSA Schedule sale upon:
- receipt of order;
- shipment or delivery;
- issuance of an invoice; or
- date payment received.
GSA Auctions Sales
Another GSA feature closely related to GSA Sales is GSA Auctions Sales.
GSA Auctions or offline sales can be used to sell agency surplus, exchange/sale, and forfeited personal property. With the following characteristics, GSA provides services that will speed up property disposal and increase returns:
- Property visibility across the country to raise interest and sales competitively;
- Specialized sales for unique products or services;
- Various sales techniques that are appropriate for an agency’s needs; and
- Vehicle consolidation sites where volume dictates.
Moreover, GSA Auctions sales offer:
- Property Disposal Computer Information Systems;
- Electronic Payments and Disbursements;
- Experience in working with contract law in the event of claims or disputes;
- Contracts for full-service vehicle disposal in all parts of the United States; and
Personal property and vehicle disposal professionals with training and expertise in sales.
GSA Support
GSA offers basic support services that include everything related to the actual sale of property:
- Acting as auctioneer;
- Working as an onsite contracting officer;
- Adding description enhancements;
- Cataloging property;
- Certifying usage;
- Collecting, depositing, and distributing proceeds;
- Maintaining registered bidders;
- Managing contract awards;
- Managing contract administration;
- Managing financial and property line item accountability;
- Offering basic media advertising (one newspaper or equivalent);
- Offering specialized sales requiring bid deposits;
- Posting items;
- Posting photos;
- Preparing award documents;
- Providing a secure Internet site;
- Publishing featured items; and
- Registering bidders.
In addition, a collaboration between GSA Fleet and the owner’s agency allows for charges for Value-Added Services such as property transportation, storage, maintenance, and reconditioning before the sale.
Conclusion
The GSA Schedule has a lot of advantages, but it also means that businesses have to deal with a lot more compliance and maintenance issues.
A crucial reporting obligation for GSA is to record sales and pay your .75% Industrial Funding Fee (IFF) every quarter. On the quote, order, and invoice, this is crucial. Ultimately, you should have a good system in place to identify between GSA Schedule and non-GSA Schedule sales.
