Consider the following key facts about GSA schedules:

  • Overall, GSA schedule sales in FY18 amounted to about $35 billion, which was nearly the same as in FY17. Sales on the IT Schedule 70 and Professional Services Schedule (PSS) 00Corp increased in FY18.
  • Small businesses make up 75% of GSA schedule contractors and obtain about 33% of schedule sales.
  • Solicitations posted on e-Buy meet the Fair Opportunity Act; there is no requirement about the number of proposals that must be received to win an award. During August and September, monitor e-Buy closely as the government spends end-of-year money during this time.

Proposals for Schedules and Awards Based on Schedules

There is some inconsistency about how Contracting Officers (COs) evaluate the schedule proposal requests pricing documentation. Know the Basis of Award (BOA) on which the pricing is based and keep it as simple as possible (see “Important Reminders”).

The government may make more than one Final Proposal Revision (FPR) request.

Whether or not COs allow escalation within the five-year option period appears to be inconsistent. The believe that escalation within the five-year period should not be allowed is based on the understanding that the BOA pricing may not be increasing. Therefore, GSA would be getting overcharged.

GSA schedules are regulated by Federal Acquisition Regulation (FAR) Part 8. This means that companies are not entitled to a debriefing for task orders or purchase orders, which is required under FAR Part 15.

Important Reminders

It is essential to know the BOA on which pricing is based and to keep it as simple as possible. This will reduce the likelihood of triggering the Price Reductions Clause (PRC). If the PRC is triggered, it must be reported. Penalties for failing to report can be stiff — including a fine of $11,000–$24,000 per invoice, possible criminal penalties, and other damages.

Schedule items are subject to the Trade Agreement Act. Open Market items are subject to the Buy American Act. Do not pay the Industrial Funding Fee (IFF) on Open Market items. In addition to overpaying, it is viewed negatively because it creates confusion for GSA.

Validity Periods

Task orders can be awarded on the last day of the GSA schedule and remain valid for up to 60 months. If you have a Blanket Purchase Agreement (BPA) under your GSA contract, awards can be issued on the BPA on the last date of validity, although services will be provided later. If the GSA schedule expires, however, the BPA expires. BPAs must have equal or more favorable terms than the GSA schedule.

GSA schedules are useful tools to obtain federal government business. The important takeaway is to know the rules and understand best practices.

If you need additional guidance, contact an MCB Advisor at 703-218-3600 or click here. To review our government contracting articles, click here. To review our tax news articles, click here. To learn more about MCB’s tax practice and our tax experts, click here.

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