Tag Archives: OIG

GSA IG Recommends Pricing Review of over 300 Migrated Professional Services Schedule Contracts

The General Services Administration (GSA)’s Office of Inspector General (OIG) published a report on March 21, 2017, titled “Audit of Price Evaluations and Negotiations for the Professional Services Schedule Contracts.” According to the IG audit, GSA’s process to consolidate eight pre-existing schedules into the Professional Services Schedule (PSS) resulted in the award of new contracts without establishing price reasonableness. Contracting officers also used a combined “Pre and Price Negotiation Memorandum” template that does not conform to Federal Acquisition Regulations (FAR) and Federal Acquisition Service (FAS) policy. Finally, contract files lack sufficient documentation to determine fair and reasonable pricing. In February 2017, GSA’s FAS initiated price reevaluations for all 322 migrated contracts to ensure prices awarded were fair and reasonable.

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From the GSA Trenches: GSA Schedule Terms and Conditions Always Rule

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!

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From the GSA Trenches: The “Trickle Down” Audit

When clients are notified they are being audited by the GSA Office of Inspector General (OIG), their first question is often what they did wrong. In reality, being selected for an audit is frequently an indication that a company is doing something right – at least as far as sales volume is concerned.

GSA’s OIG only does 40-50 pre-award audits annually and generally selects contracts that fall in the top 5% of sales for the Schedule. When only a small sample can be audited, the OIG will choose contracts that offer the most “bang for the buck” in terms of potential recoveries. In FY13, the OIG conducted 51 pre-award audits, but those contracts accounted for over 20% of total schedule revenues.

Companies with more modest sales shouldn’t take the unlikelihood of an audit as an invitation to stick their heads in the sand regarding compliance. All schedule holders should pay attention to the major findings from OIG audits, as recurring problems frequently become the basis for “trickle down” compliance efforts across the schedules program.

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GSA has Not Effectively Digitized its Schedule Contract Files

In a recent audit of Federal Acquisition Services (FAS)’s transition to electronic files, the General Services Administration (GSA) Office of Inspector General (OIG) concluded that “FAS has not effectively digitized Federal Supply Schedules contract files.” The objective of the OIG audit was to determine whether: (1) FAS completed all stages of the Federal Supply Schedules (FSS) contract digitization process, and (2) FAS’s official electronic contract files contain all contract documentation in a usable format and structure as required by federal regulations and FAS policy.

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From the GSA Trenches: Resume Reviews Aim to Identify the Utilization of Unqualified Personnel on GSA Orders

In attending recent GSA Contractor Assessment s these past several months, our team has noted an increased emphasis by GSA Industrial Operations Analysts (IOAs) on reviewing resumes. This practice impacts contractors with labor categories currently awarded on their schedule contracts. GSA requires each approved labor category to have a description that includes the minimum experience, minimum education and functional responsibility for the category. The hourly rate for each category is negotiated, in part, based on these qualifications.

The GSA Inspector General has noted on reports to Congress on the Schedules Program that the utilization of unqualified labor is a common finding during audits. As a result, IOAs are requesting to review resumes, timesheets, and other personnel documentation to compare and ensure that the contractor provides individuals who meet or exceed the level of experience and expertise approved on your GSA contract. Please note that this review may include subcontractor employees mapped to awarded labor categories on the prime’s GSA contract.

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