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Actions needed for Schedule 75 Contract holders

On January 10, GSA released plans for Mass Mod A598, and now they’re following through. Changes for Schedule 75, Office Supplies, include new business rules, new TAA compliance standards, new environmental guidance, and a new letter of supply.

Contract holders must sign the new Letter of Supply, GSA Business Rules, and Critical Information Specific to Schedule 75, and return them to GSA by the deadline on June 30, as well as supplying new TAA Operating Procedures. Otherwise, their contracts will fall out of compliance, and GSA may take action such as removal of the GSA pricelist from GSAAdvantage, or cancellation of the contract itself.

After contractors complete all required documents, they should upload the files to a new Terms and Conditions modification in eMod. GSA will then finalize the modification and incorporate into the GSA MAS Schedule Contract.

For the necessary documents, and more information, visit the solicitation. And of course, EZGSA is always here to help you with questions! Call 301-913-5000 or email mbotello@ezgsa.com.

Office Relocation SIN Relocating!

Are you a Schedule 48, SIN 653-8 contractor? This office relocation area of the Transportation, Delivery, and Relocation Schedule is disappearing into the ether, and soon. GSA has decided to consolidate two very similar SINs under two different schedules.

  • If you also have a Schedule 71 IIK contract, SIN 712-3, you are golden and don’t have much to worry about — your services are already covered under the other contract; GSA will simply cancel your Schedule 48 SIN (or the entire Schedule if 653-8 is your only SIN).
  • For those with only the single 653-8 SIN on Schedule 48, GSA will move your services onto SIN 712-3. Typical government-ese bureaucratic work will be involved, but it’s not too egregious.
  • For those who have additional SINs on Schedule 48, you have a choice of deleting the relocating SIN and keeping your Schedule, as well as applying for the 71 IIK SIN after 1 July; OR delete the other Schedule 48 SINs, canceling the contract and transitioning to 71 IIK and then re-applying through streamline for Schedule 48.

Whew. Confusing, right? Fear not, we are here to help. Give us a call at 301-913-5000, and we’ll get you through it!

Final Rule released for Common Commercial Terms

GSA Final Rule Defines Common Commercial Terms

On February 22, GSA issued a Final Rule addressing common terms that are inconsistent with Federal Law. The rule aims to streamline agreements over CSAs, EULAs, Terms of Sale, and similar sets of terms and conditions. The rule reverses several controversial provisions from an earlier Proposed Rule and class deviation by reverting the order of precedence and eliminating the requirement to provide full text of all provisions.

The rule also formalizes the longstanding stance that certain terms and conditions cannot be enforced by law via a paragraph addition to GSAR 552.212-4. The paragraph identifies 15 common commercial terms, which are viewed as non-negotiable and required by federal law. It prohibits automatic  renewals, and provides that disputes are governed by federal law. The change allows GSA to ignore these clauses during negotiations, thereby reducing time and expenses. Among the included terms are:

  • commercial supplier agreements
  • unenforceability of unauthorized obligations
  • solicitation provisions and contract clauses for the acquisition of commercial items

GSA responded well to industry complaints about the proposed rule, modifying or reversing the most egregious propositions.

For more information see the National Law Review.

Proposed Schedule 736 Enhancements

GSA Region 2 FAS Intends to Upgrade and Re-organize Schedule 736

Proposed modifications to Schedule 736 aim to make the schedule more customer-friendly and make Wage Grade Occupations and Professional Labor Categories more visible. According to the plan, there will be two primary SINs: 736-1 for Wage Grade Occupations and 736-5 for Professional Labor Categories. SIN 736-99 will remain unchanged.

The new categorization only applies to pending and not-yet-approved wage grade categories. Vendors under SINs 736-2, 736-3, and 736-4 will be consolidated into the two remaining SINs based on their current offerings. After the consolidation, those SINs will be deleted. FAS will update the solicitation to reflect all current Temp Help regulations, and contain a new ordering guide for customers.

Vendors who offer both Wage Grade and Professional Labor Rates will have to separate out their offerings. Through eMod, they should add either of the two primary SINs that apply to their offerings. Creation and submission of a new pricelist will be required, but price changes and new labor category additions are not allowed at this time.

Existing task orders will not be impacted, and will remain valid until their natural expirations. The SIN descriptions will show the entire List of Occupational Categories based on the fifth edition of the DOL Occupations Directory.

Ultimately, FAS aims to increase utilization of the schedule (as full-time hiring is becoming greatly abridged), streamline procurement and end contract redundancy, and facilitate greater capture of marketshare.

As always, if you have questions or concerns about these changes, please call our office at 301-913-5000.

Heard it Through the GSA Grapevine…

A plausible source at GSA has told EZGSA proposal specialists that the minimum yearly sales requirement for GSA Schedules is going to be increasing soon.

While this won’t be a problem for contractors that already more than meet the current sales requirement of $25,000 in the first two years and $25,000 per year subsequently, it could make it even more difficult for those businesses that struggle with selling off their Schedule.

If you need help or have questions about this increase, please contact your EZGSA proposal specialist or call 301-913-5000.