“Our revenue grew $26.8M in 4 years on the GSA Schedule Program” – Ted M.

How to Track GSA Contract Compliance

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GSA contract compliance is critical to avoid penalties, maintain your contract, and build trust with federal customers. Here’s what you need to know:

  • Key Requirements: Track sales, report accurately, pay the Industrial Funding Fee (IFF), follow the Price Reductions Clause, and keep administrative records updated.
  • Tools for Success: Use contract management software, set up a compliance calendar, and organize a document repository for easy access.
  • Internal Audits: Regularly review your compliance efforts to prepare for GSA assessments and address issues early.
  • Professional Help: Consider hiring GSA compliance experts to simplify the process and reduce risks.

Contract Administration & Compliance (CAC) Recorded Webinar

Key GSA Compliance Requirements

To keep your GSA Schedule contract in good standing and avoid penalties, you need to meet specific compliance requirements. These fall into three main areas: sales tracking, pricing compliance, and administrative documentation.

Sales Tracking and Reporting

Accurate sales tracking and timely reporting are critical for staying compliant. Contractors must keep detailed records of all GSA Schedule sales and submit reports through the Federal Acquisition Service Sales Reporting Portal (FAS SRP). Reporting frequency depends on your contract type:

  • Non-TDR contracts: Submit quarterly reports, due at the end of the month following each quarter.
  • TDR contracts: Submit monthly reports.

The Industrial Funding Fee (IFF) – a 0.75% fee based on reported sales – must be calculated correctly and paid on time. Even if you have no sales, you’re required to submit a $0 report to remain compliant.

Pricing Compliance and Price Reductions

Pricing compliance revolves around the Price Reductions Clause (GSAR 552.238-75) and maintaining fair pricing relationships with your Basis of Award (BOA) customers. BOA customers typically receive the best discounts and are considered your Most Favored Customers (MFC).

"If you do not submit a modification to do so, and a GSA customer makes a purchase at the old 15% discount, GSA will consider that to be an overcharge and could assess penalties for that." – Winvale Team, GSA Contracting Experts [1]

You must notify your Contracting Officer within 15 days of any price changes, including catalog updates, new discounts, or special offers that might affect your BOA pricing relationships.

Administrative and Document Requirements

"Fundamental compliance requirements come with having a GSA Schedule contract." – Aprio, LLP [1]

Contractors need to keep thorough records of contract modifications, sales data, BOA pricing, product or service offerings, and administrative updates. GSA Advantage! catalogs must be updated at least every two years – or within 30 days of any relevant changes. Additionally, Mass Modifications must be reviewed and accepted within 90 days of release.

Each invoice must include the following details for proper documentation:

  • GSA Contract Number
  • DUNS Number
  • Special Item Number (SIN)
  • Part Number and/or Service Description

Meeting these requirements is just the first step. Building a reliable system to track and manage compliance will help you stay on top of these obligations.

Setting Up a Compliance Tracking System

Once you’re clear on the key compliance requirements, the next step is to create a system that ensures you consistently meet them.

Choosing Contract Management Software

Contract management software can make compliance easier by automating tasks like sales reporting, IFF calculations, and tracking deadlines. When picking software for GSA contract management, look for tools specifically tailored to federal contracting.

Features to look for include:

  • Automated sales reporting and IFF calculations
  • Built-in compliance deadline tracking
  • Document storage and organization
  • Price monitoring tools
  • Modification request management

Focus on software that’s easy to use and integrates well with your current accounting systems. This ensures accurate tracking and reporting without unnecessary complexity.

Creating a Document Repository

A centralized document repository is essential for organizing all GSA contract-related materials. Set up your repository with clearly defined sections for:

  • Contract documents and modifications
  • Sales reports and IFF payment records
  • Pricing documentation and BOA customer details
  • Correspondence with GSA officials
  • Audit-related files

Use consistent naming conventions and version control to keep everything organized. Opt for secure, cloud-based storage solutions to ensure easy access while protecting sensitive information.

Setting Up a Compliance Calendar

A compliance calendar keeps you on top of important deadlines and requirements throughout the contract term. Include key dates like:

Reporting Type Deadline
72A Reports (Non-TDR) January 30, April 30, July 30, October 30
IFF Payments 30 days after quarter end
GSA Advantage! Catalog Updates Every 2 years minimum
Mass Modification Reviews Within 90 days of release

Set reminders at least two weeks before deadlines to allow time for preparation. Update the calendar monthly to reflect any new requirements or changes.

For smooth calendar management:

  • Assign specific compliance tasks to team members
  • Build in preparation time before deadlines
  • Document completed tasks for audits
  • Conduct regular internal reviews to confirm compliance

With these systems in place, you’re ready to move on to regular reviews and audits to maintain adherence to GSA requirements.

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Conducting Internal Compliance Audits

Regular internal audits play a key role in staying compliant with GSA Schedule requirements and preparing for official Contractor Assessment Visits (CAVs). Industry data shows that companies with strong compliance systems resolve potential issues up to 40% more effectively before they become major problems.

Preparing for GSA Assessments

Having a reliable compliance tracking system makes internal audits smoother by organizing all necessary documents and deadlines. Pay attention to these critical areas:

Audit Focus Area Key Elements to Review
Documentation & Administrative Contract SF1449, FPRL, Current Pricelist, Modifications, Document Retention, Training Records
Sales Tracking Quarterly Reports, IFF Payments, Sales Practice Analysis
Pricing Compliance Price Reductions Clause, Commercial Sales Practices

"Spend an adequate amount of time becoming organized and becoming prepared for your next CAV meeting – it’s an audit. The stakes are high and if any critical element is deficient your business could potentially result in adjustment of pricing, claims for recovering funds, or the cancellation or non-renewal of your GSA Schedule." – Coley GCS

Key preparation steps include:

  • Organizing documentation and addressing any previous findings.
  • Getting your team ready by ensuring key members understand their roles during the audit.

Resolving Compliance Issues

Spotting and fixing problems early is essential for effective compliance management. Leo Alvarez from Baker Tilly explains:

"Although the compliance review and historical pricing analysis can be time consuming, the effort pales in comparison to management’s distraction and the potential financial impact of an adverse audit report from the GSA OIG."

Focus on these practices to maintain compliance:

  • Conduct regular, thorough reviews of your GSA Schedule compliance.
  • Keep your documentation up-to-date and ready for audits.
  • Train staff specifically for audits like CAVs to ensure they’re prepared.

Assign a GSA Compliance Officer from your accounting or finance team to oversee these efforts. This person will be responsible for monitoring compliance, ensuring accountability, and managing key areas like GSA order segregation and discounting policies. Their role is essential to keeping your systems on track.

Using Professional Support for GSA Compliance

Navigating GSA contract compliance can be tricky and time-consuming. Professional support services help ease the load, ensuring compliance is handled accurately while saving you time.

What GSA Focus Brings to the Table

GSA Focus

GSA Focus specializes in managing GSA contracts with a well-organized approach covering document management, compliance checks, administrative tasks, and contract oversight. Their process helps businesses meet requirements efficiently while minimizing compliance risks. Here’s a breakdown of their services:

Service Area What They Provide
Document Management Automated document prep, secure online storage, and a well-organized filing system
Compliance Monitoring Regular checks, tracking regulation updates, and preparing for audits
Administrative Support Less paperwork, smoother workflows, and more time for other priorities
Contract Management Expert help with negotiations, pricing oversight, and sales tracking

Making Compliance Easier with GSA Focus

For small businesses, keeping up with GSA compliance can feel overwhelming. GSA Focus steps in to simplify the process by offering automated tools, expert advice on tricky requirements, and proactive monitoring to catch problems before they grow.

They tailor compliance systems to fit your business needs, ensuring proper management of critical tasks like:

  • Industrial Funding Fee (IFF) payments
  • Quarterly sales reports
  • Monitoring price reductions
  • Keeping essential documents organized

"The effort invested in proper compliance management pales in comparison to the potential financial impact of adverse audit findings. Professional support services can significantly reduce this burden while ensuring accuracy and timeliness."

Conclusion: Sustaining GSA Compliance for Success

Maintaining GSA compliance requires well-structured systems, ongoing effort, and a clear strategy. Important steps include precise sales tracking, routine internal audits, organized record-keeping, and staying updated on GSA regulations. Combining these practices with expert advice can help contractors handle the challenges of GSA compliance effectively [1].

Tools like contract management software, compliance calendars, and document repositories can play a key role in staying compliant [1]. These solutions help contractors avoid common mistakes and stay aligned with GSA requirements.

As mentioned earlier, professional support can make navigating GSA compliance much easier. For small businesses aiming to thrive in federal contracting, working with experienced GSA compliance specialists offers valuable insights and tools. These partnerships allow businesses to focus on growth while meeting federal standards [2].

GSA compliance goes beyond just meeting obligations – it lays the groundwork for long-term success in federal contracting. With consistent effort and the right support, contractors can not only stay compliant but also unlock more opportunities in the government marketplace.

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