Federal contractors, don’t forget that three important reporting deadlines are coming up this month! For GSA Schedule contract holders, the deadline for 72A Sales Reporting and IFF remittance is Sunday, October 30th. You must report, even if you have zero sales in the preceding quarter. Log in to the 72A Reporting website to complete these action items.
For contractors who have an approved small business subcontracting plan on an active federal contract, the Individual Summary Report (ISR) and/or Summary Subcontracting Report (SSR) must also be submitted by Sunday, October 30th. Reports are required regardless of whether there has been any subcontracting activity. Log into the eSRS system to complete your ISR and/or SSR.
Finally, companies with service contracts containing FAR 52.204-14 or 52.204-15 (which includes GSA Schedule holders), must complete their Service Contract Report (SCR) in the System for Award Management (SAM) by Monday, October 31st. You can find more detailed information about the SCR requirements, including submission instructions, in this blog.
A failure to meet service contract reporting requirements may result in the government finding a contractor non-compliant. In accordance with FAR Subpart 4.1704,“If the contractor fails to submit a report in a timely manner, the contracting officer shall exercise appropriate contractual remedies…[and] make the contractor’s failure to comply with the reporting requirements a part of the contractor’s performance information” in the Contractor Performance Assessment Reporting System (CPARS).
Should you have any questions or concerns regarding these reporting requirements or deadlines, please contact Jennifer Aubel at email@example.com 301.231.6253.
Digital certificates, which authorized negotiators must maintain in order to access GSA’s online contracting environment, will now also be needed to report contract sales and remit the Industrial Funding Fee (IFF) for contracts participating in the Transactional Data Reporting (TDR) pilot (see our blog for information about the current rollout schedule for this program). GSA’s Level 3 PKI digital certificates are issued by one of two approved vendors, are specific to the individual named on the certificate, and are valid for two years. Department of Defense ECA certificates also work in GSA systems.
Contractors participating in TDR will be required to report transactional sales data to GSA monthly and to remit the IFF on those sales either monthly or quarterly, as the contractor elects, through GSA’s new FAS Sales Reporting portal. Contractor points of contact authorized to report and pay IFF will be required to possess valid digital certificates in order to access this site. GSA has provided guidance and a tutorial on sales reporting for contractors who switch to TDR. However, you must have a valid digital certificate for GSA in order to access the guidance and tutorial site.
In a webinar to discuss its Transactional Data Reporting (TDR) pilot program, GSA announced tentative dates for the issuance of the mass modification (A509) to implement the pilot program for affected schedules. As discussed in Aronson’s previous blog, schedule holders who participate in the TDR pilot will be required to provide monthly contract sales reports, including prices paid information, to serve as the basis for pricing negotiations. In exchange, GSA will eliminate the requirements for those contractors to provide Commercial Sales Practices (CSP) and track commercial prices to a Basis of Award customer for price reductions. The following dates are subject to change:
Acceptance of this mass mod is OPTIONAL during the pilot, unless the GSA contract renews during the pilot period. Contractors must respond to the mass mod whether they plan to enroll in the pilot or not by accepting or declining the mod.
Transactional data must be reported monthly. IFF remittance is still required quarterly, although contractors participating in the pilot now have the option to remit IFF monthly. If and when contractors accept the TDR pilot program mass mod, transactional data reporting will be required at the start of the next calendar quarter. This quarterly timeframe will allow for a smoother reporting transition from the 72a Quarterly Reporting System to the new FAS Sales Reporting system.
Contractors can register for the third GSA-hosted webinar on TDR held on Tuesday, August 23 here. Please contact Barbara Connell (240-364-2657, firstname.lastname@example.org) or Jennifer Aubel (301-231-6253, email@example.com) if you have any specific questions about this significant change or other GSA Schedule compliance matters.
Contractors holding GSA Multiple Award Schedule (MAS) contracts are required to report quarterly all contract sales, and remit 0.75 percent of sales back to GSA as an Industrial Funding Fee (IFF). The 0.75 percent IFF is added on top of negotiated contract prices, so that the ordering customers actually pay the fee and the contractor passes them through. As explained in General Services Administration Acquisition Manual (GSAM) clause 552.238-74, Industrial Funding Fee and Sales Reporting, “The IFF reimburses [GSA’s Federal Acquisition Service] for the costs of operating the Federal Supply Schedules Program. FAS recoups its operating costs from ordering activities as set forth in 40 U.S.C. 321: Acquisition Services Fund.”