On February 7, the General Services Administration (GSA) hosted a roundtable panel event to discuss its pilot program under the Transactional Data Reporting (TDR) rule. The discussion included Kevin Youel Page, the Deputy Commissioner of GSA’s Federal Acquisition Service (FAS); Judith Zawatsky, the Director of GSA’s Multiple Award Schedule (MAS) Program Management Office; Elliott Branch, the Deputy Assistant Secretary of the Navy (Acquisition & Procurement); and Larry Allen, the President of Allen Federal Business Partners.
Are you ready for 2017? Year-end is a great time to brush up on those important business topics that get neglected during busier times. Aronson’s Government Contract Services Group is pleased to bring you our top Fed Point blog posts of 2016, written to help you STRATEGIZE to achieve your growth, OPTIMIZE your operations, and REALIZE your goals.
Also be sure to visit the Aronson Knowledge Center, for free recorded access to all of our 2016 webinars on topics that include driving M&A value, managing cost type contracts, contract closeouts, GSA Schedule compliance, IT Security, and much more!
Not following the terms and conditions of your GSA Schedule Contract can cost you big $$$!
Scenario One: You receive an RFQ from a Federal Government procuring agency that will utilize your GSA Schedule contract on a re-compete for work your company is already performing for this customer. The RFQ lists the labor category title, education and experience requirements for the work, including a Senior Network Engineer that requires a Bachelor’s Degree and 10 years’ experience. Your Senior Network Engineer GSA labor category requires a Bachelor’s Degree and 8 years’ experience, but the person you are proposing in the category is familiar with the work being performed at the agency. The agency’s personnel are familiar with this resource and like the work that she has done in the past. The agency personnel say, it’s fine if you use your person with 8 years’ experience as a substitute for our agency requirement of a person with 10 years’ experience. It sounds harmless enough. The agency has agreed, so you’re in the clear, right? Wrong!
One of the most common criticisms of the GSA’s Multiple Award Schedules (MAS) program is that the pricing on schedule contracts just isn’t competitive. Whether justified or not, the perception of high pricing is pervasive. In fact, the Department of Defense issued a class deviation to the FAR obligating its contracting officers to make a price reasonableness determination on all GSA orders using FAR Part 15 price analysis techniques.
In this environment, it’s easy to understand why contracting professionals may hesitate to use the Schedules, even if it means giving up the benefits of a streamlined acquisition method. If you’re feeling a little gun-shy about using the Schedules, here are five online tools you can use to make sure you secure better pricing on your next GSA purchase:
The Service Contract Labor Standards (SCLS), formerly known as the Service Contract Act (SCA), interaction with GSA Schedules has for a long time been a source of confusion for many contractors. In the past few years, GSA has been ramping up its role in promoting SCA compliance at the schedule level, but now GSA is implementing changes to update how SCA is applied to the GSA Schedules program.
In June 2016, GSA Schedules offering services will be refreshed to remove all wage determinations (WD), and to add the requirement that WDs are incorporated at the task order level. Incorporating WDs at the task order level will ensure that the most recently released WD, for the location where the work is to be performed, is incorporated into the task order. All services schedules will still contain the applicable SCA clauses. Click here for GSA’s FAQ document regarding the changes.
Removing WDs at the schedule level will necessitate several changes which Aronson will outline in a future blog when all the details are known in the refreshed solicitations. Please continue to monitor Aronson’s Fed Point blog for emerging developments on this topic.