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Contract management

News You’d Rather Not Use…

Our sources throughout the GSA product schedules are indicating that the recent process for submitting a modification to the CO for approval before actually submitting it through eMod will be codified in the next round of Schedule refreshes.

While this will cut down on a CO’s official modification time in-house, it will probably mean longer wait times for contractors to obtain mod approval, as there will be no clock measuring the time that the CO will have the mod pre-submission.

We are hopeful that this analysis is incorrect, and your CO will understand that your Schedule modifications require timely approval and only assist the contractor in selling more products to the government. Hopeful….

Alert!

All GSA Schedule holders with Contracting Officers stationed in Texas should be aware that their COs will be in training next week, 24-28 April. They will most likely be unavailable to you for questions and modifications.

Ch Ch Ch Changes … to the GSA Schedules

GSA is preparing to release a round of Schedule refreshes next month, so prepare for a bunch of mass modifications. And if you are in the midst of completing your GSA Schedule proposal, either submit now or expect to review the entire solicitation again come April.

New policies represented in the GSA Schedules will include small business subcontracting changes, updates to those entities that can access the Schedules for purchases, SCA adjustments, and modifications in the Disaster Purchasing Program. For instance, the Red Cross and other qualified organizations will have access to the Schedules during emergency preparedness and disaster relief. Additionally, the following specifics may be of interest to our clients:

  • Subcontracting plans for ‘other-than-small’ businesses will now be at the CO’s discretion. For all intents and purposes, however, these will still have to be submitted with your proposal.
  • The Pathways to Success training has been removed as a requirement for streamlined offers.
  • Montenegro and New Zealand are now TAA compliant countries.
  • Federal contractors now receive paid sick leave.

If you have any questions about how these changes will affect your Schedule contract, feel free to give us a call at 301-913-5000. We look forward to assisting you with this new round of changes.

Scared of the CAV or IOA?

Is your GSA Schedule in good health? The government ensures that your GSA Schedule stays sound by performing occasional audits, checking that your business is following the rules under which the contract was awarded. While you may have the best intentions of remaining in compliance, new hires, misunderstandings about regulatory requirements, and price changes can trip you up, causing problems in the audit itself.

EZGSA offers a Schedule Check-Up that helps to prevent negative audit findings. Many of our clients utilize this service once a year, just as you get a physical once a year — as an objective view of your GSA Schedule’s soundness.

In the GSA Schedule Check-Up, we review:

  • invoices;
  • sales to your Most Favored Customer;
  • sales to all government agencies;
  • internal Commercial Sales Practices procedures;
  • 72A reporting and payments; and
  • open market sales.

If discrepancies are found, we assist you in correcting the problems as well as developing new procedures that will prevent replication of the problems.

Contact us at 301-913-5000 or sales@ezgsa.com to see if your business can benefit from a Schedule Check-Up, either as a yearly preventative or before the Auditor visits.

FAR Update

FAR Subpart 4.17, Service Contracts Inventory, requires service contractors with contracts containing either FAR clause 52.204-14 or 52.204-15 to submit a Service Contract Report (SCR) to the System for Award Management (SAM.gov) at the end of each Fiscal Year.

FAR clauses 52.204-14 and 52.204-15 should be contained in all of the following types of service contracts:

  • Cost-reimbursement, time-and-materials, and labor-hour service standalone contracts or orders with a total value above the simplified acquisition threshold (SAT);
  • Fixed-price definite-delivery service contracts with a total value at or above $500,000;
  • Indefinite-delivery contracts where the estimated total value meets either of the above criteria; and
  • First-tier subcontracts for services.

The initial service contract reporting window will remain open until December 15, 2016, and all service contractors are encouraged to submit their responses during that time-frame.  

It is extremely important that all service contractors comply with the reporting requirement. Contractors should be reminded that a failure to comply with the service contract reporting requirements must be documented as part of a contractor’s performance evaluation as required by FAR Subpart 42.15.

Further Information:

Please follow this link for an instructional GSA YouTube video on the SCR submission process.

Please review the SCR Quick Start Guide.

If you have any questions, please contact us at info@ezgsa.com or 301-913-5000

https://youtu.be/kMbcM9myWjo