What Does GSA Compliance Mean?
GSA Approval is a non-industry specific status for organizations that manufacture and sell products to the United States Government through the General Services Administration (GSA). Established in 1949 by then-President Harry Truman, the General Services Administration aims to speed up government supplies procurement. It eliminates administrative work for talks for acquisition among federal agencies and corporations.
What is GSA Compliance?
In government contracting, words that are, at first glance, easy to understand or self-explanatory often have underlying meanings induced within them. To fully grasp and understand GSA compliance, it is essential to look into what it means to be GSA compliant, check if you adhere to GSA compliance and the consequences of not being in GSA compliance.
GSA Office of Policy and Compliance
According to the GSA Chief Acquisition Officer’s policies, the Office of Policy and Compliance is responsible for laying the standards and framework for running the acquisition workforce. Additionally, the Office of Policy and Compliance is also responsible for leading, supporting, and facilitating the review of Federal Acquisition Service (FAS) programs and initiatives.
The Federal Acquisition Service (FAS) is an organization bound by integrity, dedicated to facilitating a positive customer experience by taking charge of Acquisition Management.
Furthermore, the Office of Policy and Compliance spearheads the promotion of quality and integrity throughout the acquisition procedure and ensures the consistency of acquisition practices. This office offers program-wide consultation as the GSA Schedules Program Manager and guarantees that FAS takes necessary regulatory compliance steps.
How to Check GSA Compliance
GSA’s Vendor Support Center is an excellent all-around resource that guides you on how to be in GSA compliance on your GSA Contract. The following are the categories to check for you to find out if your GSA Compliance level is still sufficient:
Scope Compliance
To check for GSA Compliance by scope compliance, put in mind and always ask yourself whether or not the services or products that you are offering fall within the item descriptions of the Special Item Number (SINs) that you get awarded. It is also imperative to know which services or products you provide get authorized under your contract.
Staying within the scope of your contract is a crucial contractor performance factor. Government-wide initiatives aiming to educate both GSA Schedule customers and GSA Schedule contractors ensure that quotes and orders fall within the contract’s scope in use.
Invoicing Requirements
Every GSA Schedule contract has invoicing requirements stipulated in the contract. The GSA contract’s market items must be identified by the contractors to their customers, especially if orders get combined with GSA contract items.
Contractor Assessment
Contractor assessments are usually conducted depending on several factors, including sales volume.
Purpose of an Assessment
Assessments work to help you succeed as a contractor. The GSA Industrial Operations Analyst (IOA) will verify that you are in GSA compliance with critical clauses stipulated in your contract. Additionally, the IOA can be a valuable educational resource for contractors.
How to Prepare for an Assessment
The IOA will contact you by phone, email, or both. The actual assessment may be done face-to-face or virtually, as deemed necessary by the IOA. The IOA will also identify the documents you will need to have for the evaluation, such as:
- The original and final revision of the Multiple Award Schedule Contract
- All approved modifications and price-lists
- Any Blanket Purchase Agreements (BPAs)
- Letters-of-supply and country-of-origin information
- Listing of all GSA-authorized dealers
- Sales tracking system SOPs
- GSA and non-GSA proposals, invoices, and statements of work
During the assessment, it is also imperative for all appropriate personnel to be present.
What to Expect
On the day of the assessment, the IOA will ask questions concerning your company’s contract and the steps and initiatives you have taken to uphold the agreement successfully. Queries may revolve around but are not limited to:
- Sales tracking system
- Compliance with the Trade Agreements Act
- Scope of Contract
Contractor Assessment Report
After the IOA’s assessment, the report is almost always available to both the contractor and the contracting officer. The information will show your firm’s ability to uphold binding terms and conditions, as well as highlight your firm’s areas of potential concern. The Contractor Assessment Report provides contractors with useful feedback and criticisms on how they fare with complying with GSA Schedule contracts.
Contractor Teaming Agreement (CTA)
GSA Multiple Award contractors are allowed to form a Contractor Teaming Arrangement (CTA) using their contracts. This teaming agreement enables two or more contractors to work side by side in meeting agency prerequisites for orders that they may have disqualified for independently. CTA members benefit by acquiring reportable sales for their contracts. Also, customers benefit from buying a total solution in one purchase without transacting with more contractors.
Trade Agreement Act (TAA) Compliance
The Trade Agreement Act ensured the U.S. government needs to acquire only U.S-sourced end products. This Act means that the end products you offer through your GSA Schedule must not be made in certain countries, including but is not limited to China, India, Indonesia, Iran, Iraq, Malaysia, Pakistan, Russia, and Sri Lanka.
Labor Qualification Compliance
Multiple Award Schedule (MAS) contractors offering professional labor categories must demonstrate the human resource they provide under each GSA task meets minimum qualifications in adherence to their contract.
Federal Acquisition Regulations
The Federal Acquisition Regulations (FAR) layouts uniform policies and procedures in acquiring supplies and services by Executive Agencies.
Strategic Partner Delivery (SPD)
The Strategic Partner Delivery (SPD) results from the transformation of a Supply Transformation (ST) initiative designed to modernize wholesale and retail business programs from being a GSA stock-based fulfillment model to a direct vendor-to-customer delivery model.
Other categories to consider in determining GSA Compliance are Most Favored Customer/Basis of Award and Learning More about Mandatory Order Status.
What to do if You are NOT Compliant
The consequences for not being in GSA Compliance can range depending on the magnitude of incompliance. Penalties and monetary fines are common, but consequences can be as severe as contract cancellations or even corporate suspension or debarment in worst-case scenarios.
Conclusion
Although seemingly laborious, GSA Compliance and upholding GSA Schedule contracts can be worthy and beneficial. Additionally, staying on the law’s side will always be preferable to running the contrary’s risks.
