GSA and DoD Help Customers With Increased Costs

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This content is a continuation of the blog:  Help My Costs Have Increased! Published on March 30, 2022.

With nationwide inflation at 10%, federal contractors are finally getting some additional relief from the General Services Administration (GSA) and the Department of Defense (DoD). 

ClearCoast applaudes the initiatives of the recently released guidance by these agencies to help companies, particularly small businesses, who have been particularly impacted by the inflationary costs and global supply chain delays.  Contracting agencies will benefit from these initiatives providing continued access to the commercial market through existing contracts including the MAS GSA Schedules program.

GSA updates its guidance for how quickly contracting officers can raise prices on the schedule

Jeff Koses, GSA’s senior procurement executive, and Mark Lee, the assistant commissioner in the Office of Policy and Compliance in GSA’s Federal Acquisition Service, told contracting officers on September 12 that they do not need additional approvals to invoke the economic price adjustment (EPA) clause in GSA contracts.  The updated GSA guidance memorandum, MV-22-02, Supplement 1, is available at https://www.gsa.gov/policy-regulations/policy/acquisition-policy/acquisition-policy-library-resources

“For EPA increases exceeding the ceiling percentage established in the solicitation, Acquisition Letter MV-22-02 initially lowered the approval level from the contracting director to one level above the contracting officer. This supplement, in recognition of ongoing price volatility and impacts to the global economy, removes the requirement to obtain additional approvals,” the memo stated. “This means that all requests for EPA increases can be approved by the contracting officer, whether above or below the ceiling percentage established in the solicitation. Contracting officers should review all EPA requests consistently and in line with the terms of the underlying contract.”

Koses and Lee’s updated guidance makes it clear that speed without reducing rigor is important.

“This temporary moratorium does not diminish a contracting officer’s responsibility for reviewing EPA requests and asking for additional information, if applicable, within the confines of what is normally necessary for processing EPA requests. Specifically, EPA requests must be evaluated to ensure the request is justified,” the memo stated.

This updated guidance is effective immediately and will remain in effect until March 31, 2023, unless otherwise extended.

DoD releases second memo to deliver relief to Contractors due to inflation

On September 12, the DoD also updated guidance for Contracting Officers regarding approaches for addressing inflation under existing firm-fixed-price contracts.

The updated guidance is based on feedback from the Department’s acquisition executives about how inflation is presently affecting the defense industrial base and contractors’ ability to perform under existing firm-fixed-price contracts. The memorandum advises Contracting Officers about the range of approaches available to them to make potential accommodations including schedule relief and amending contractual requirements, and in extraordinary circumstances, the use of Extraordinary Contractual Relief.

As conditions warrant, DoD will continue to adapt its approach to meeting mission requirements through the current economic environment.  

The updated DoD guidance memorandum is available at https://www.acq.osd.mil/dpap/policy/policyvault/USA001773-22-DPC.pdf

WE’RE HERE TO HELP.

For questions about EPA requests to your GSA MAS contract reach out to ClearCoast today.  Hire a GSA Consultant who serves as your best partner.

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About ClearCoast

ClearCoast USA, LLC brings over 30+ years experience in the business-to-government (B2G) industry.  Since 2000, ClearCoast has helped 200+ clients qualify for a GSA MAS Contract.

Before Hiring a GSA Consultant Ask These 5 Questions

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So, you are interested in a GSA Multiple Award Schedule (MAS) contract? Your government customer said that you should get ‘on contract.’  Or one of your competitors is leveraging opportunities by being a ‘pre-approved’ vendor (part of the club so to say). Or you have decided these challenging economic times call for a shift or pivot into the government industry to transfer your commercial expertise, products, and/or services. Never has there been an unprecedented amount of dollars flowing to federal, state, and local government agencies.

“Navigating the world of getting a GSA Contract is not for the faint of heart.”  That’s Normena Walton, Sr Contract Specialist at IHS Markit, the leading source of information and insight in critical areas that shape today’s business landscape.

You can seek to qualify for your own GSA MAS contract, however, consider what you do not know. On the surface, this may seem like a very straightforward process. When the rubber meets the road, you may find that it will not be the case. In terms of lost time, allocation of internal resources, missed opportunities and risk of rejection, it typically costs a company more overall to acquire and handle the GSA MAS proposal process in-house. 

The real success stories come from companies who understand what to look for when interviewing a GSA Consultant to help provide a ‘clear’ path to obtaining a comprehensive, flexible, and profitable GSA MAS Contract.

Here are 5 Questions you should ask a company providing GSA Consultant services to make sure they have your best interest in mind and can deliver a viable and lasting contract.

Question 1: HOW MUCH EXPERIENCE DOES THE CONSULTANT HAVE SPECIFICALLY WITH GSA CONTRACTS?

Helping companies qualify for a GSA MAS contract requires knowledge acquired through experience. It is truly a specialty niche area within government contracting.  Be sure to ask:

  • Who will specifically be preparing, negotiating, and getting YOUR contract through the process?
  • How much experience does that individual possess?
  • What is their specific track record with new GSA contract awards?
  • Why do they believe they are best suited to work with your company?
  • Do they possess experience with GSA offers in your specific industry vertical?

It is critical that you speak with the GSA consultant who will represent your company. Inexperience can result in errors causing your proposal to be rejected.

According to GSA, 60% of all offers are initially rejected. Investment in a well experienced and knowledgeable GSA Consultant who understands the nuances of the GSA MAS program is essential.  

Question 2: DOES THIS GSA CONSULTANT TAKE TIME TO UNDERSTAND YOUR GOALS AND OBJECTIVES UP FRONT?

Interview several companies to find the right partner. Look for a consultant that is asking about your goals and objectives. If they are quick to start ‘selling what they do’ before getting to know your company – that’s a red flag.

  • Are they interested in why you want to get a GSA MAS Contract?
  • Are they helping you to confirm that this path is a good one now?
  • Did they ask what you specifically want to accomplish with obtaining a GSA MAS Contract, such as:
  • Leverage current presence in government market?
  • Jump into the government market as a new vendor?
  • Find a better way to win contracts instead of the painful RFP process?
  • Do they understand your unique challenges? Large Business? Small business? Veteran Owned Business? Woman Owned Business?

A good GSA Consultant is more interested in your goals and success than communicating the details of how they do what they do. Yes – all that will come eventually. But if out of the gate, you don’t feel the love so to say – then best to move on. 

As John R. Crocker, Managing Partner, Enterprise Iron Financial Industry Solutions, Inc., says, “We interviewed a couple of firms to qualify for a GSA Contract who made us feel as though they wanted to just shove us into an assembly line. We wanted a company that didn’t run a ‘cookie cutter’ process.”

Question 3:  IS THERE A FORWARD-THINKING STRATEGY FORMULATED UPON KICKOFF?

Getting a GSA MAS Contract is far from completing an application. The turbo template approach will not cut it in a vetting process that is more in depth than any current competitive bid for a government contract. 

Following the MAS Roadmap presented by GSA identifies the blocks of information required. However, it’s what you don’t know that you don’t know that will result in either a viable and profitable contract or one in which your company is forever playing catchup with your offerings and pricing.

  • Is your hired GSA consultant asking about your products and services from a market share perspective?
  • Do they understand how interpret commercial sales practices?
  • Are they seeking to maximize margins? Limiting compliance risk?
  • Do they understand how to tell your story?
  • Have they conducted a detailed market analysis of product/service offerings to guide your proposed pricing to GSA?
  • Are they prepared with a strategy to deliver an offer which represents real value to the government but delivers recognizable revenue and success for you?
  • Have they discussed future growth and how this GSA Contract fits within the wider context of government contracting?

A forward-thinking GSA Consultant collaborates with you and your team to carve out a thorough and concrete strategy, and the plan to carry it out. No two companies are alike. There is no one size fits all. And no contract offer is boilerplate. Look for a GSA Consultant who can develop an individually tailored GSA strategy to ensure your offer travels through the process to achieve desired outcomes.

Question 4:  WHAT IS THE PROJECT MANAGEMENT PLAN FOR THE PROCESS TO QUALIFY FOR GSA?

Ask the GSA Consultant how will they manage the process through the life cycle stages of qualifying for a GSA Contract and beyond. It is important to understand your company’s role and responsibilities throughout the process. Setting the right expectations is key.

  • Does the GSA Consultant ensure that you understand the big picture first?
  • What GSA offerings or MAS large categories will be pursued?
  • Do they have a project checklist to manage data requirements, action items, tracking of completed tasks, etc?
  • Has a targeted submission date been discussed in advance to drive proposal activities tied to a project timeline?
  • What is the communication strategy between your company and the GSA Consultant?
  • Weekly calls or virtual meetings? Who will be the participants?

If a GSA Consultant doesn’t have a plan for how to manage the project then be weary.  This is when things fall through the cracks.  Your GSA Consultant is responsible to keep things moving to ensure clarity of focus in preparing and submitting a comprehensive offer. A great GSA Consultant leaves no stone unturned.

Question 5:  DOES THIS GSA CONSULTANT GO ABOVE AND BEYOND??

In today’s competitive world, it’s not enough to just be good or average.  You have to be great.  And you need partners who think about greatness in the same way by going above and beyond. Find a GSA Consultant who brings broader knowledge to the table beyond just getting a GSA Contract and wishing you good luck. 

  • What post award services will help your company leverage this newly awarded GSA Contract?
  • Is there post-award training to jump start the sales team to go after opportunities?
  • How does the sales team educate their federal, state and local government customers on the use of the GSA Contract?
  • What administrative internal tasks are required to stay compliant with the contract?
  • Are contract maintenance and management services for price adjustments, new offerings or other modifications provided to support our contract?

“As a Service-Disabled Veteran Owned Small Business (SDVOSB), we needed someone to teach us solid B2G strategies that worked.” That’s Parish Morris, Military Veteran, CEO, Document Security Solutions, in response to next steps after getting a GSA Contract.  “We needed a company who could serve as a small business matchmaker and leverage our past performance in discussions with our government client network.”

WE’RE HERE TO HELP.

Hire a GSA Consultant who serves as your best partner.

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About ClearCoast

ClearCoast USA, LLC brings over 30+ years experience in the business-to-government (B2G) industry.  Since 2000, ClearCoast has helped 200+ clients qualify for a GSA MAS Contract.

Should Manufacturers Get A GSA MAS Contract?

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As the most widely used government contract vehicle, the GSA Multiple Award Schedule (MAS) is a valuable tool for manufacturers and their channel partners (i.e., distributors, value added resellers/dealers). By streamlining the buying/selling process, a GSA MAS Contract offers a pathway for these industry partners to deliver their innovative products and support services quickly to the government.   

Option 1:  Manufacturer and Channel Partners Hold a GSA MAS Contract

As the GSA MAS program has grown over the past few decades, GSA was eager to bring in as many industry vendors as possible.  This resulted in situations we see today where the manufacturer, distributor and VAR/dealers are simultaneously holding GSA MAS contracts for the exact same product line, more specifically the same part number. 

The price disparity created due to the varying margins results in significant differences in the final GSA Price to government customers for the same part number.  Most of the time, it’s the VAR/dealer who gets the short end of the stick as they are unable to compete with the lower pricing offered by the distributor or worse the manufacturer.

Historically, there was a clear line of outreach to the direct end user honored by manufacturers, distributors, and their VARs/dealers.  With the blurring of that line due to economics and the desire to control pricing and margins, manufacturers still seek to qualify for a GSA MAS contract without fully understanding all the ramifications. 

Here are some of the problems with this option in which the manufacturer and channel partners hold a GSA MAS Contract:

  • A Letter of Supply (LOS) must be issued by the manufacturer to their channel partners for selling the manufacturer’s products on the channel partner’s GSA MAS Contract.  For years, lack of oversight or permission for the issuance of an LOS resulted in vendors selling a product line unbeknown to the manufacturer. 
  • Manufacturers found themselves sending ‘cease and desist’ letters to these vendors to remove their products from their MAS GSA contracts.  These unauthorized vendors selling at rock bottom prices further exasperated the pricing issues. 
  • Manufacturers who compete directly with their channel partners show little trust in their relationships with these partners.  They are happy to compete and let the cards fall where they may in a cut-throat approach to business.
  • The business model for a manufacturer is not set up for compliance requirements with a GSA MAS contract.  The contract administrative and maintenance tasks are foreign to manufacturers including proper quoting, invoicing, tracking of sales, reporting of sales, subcontract goals and reporting, understanding mass modifications, etc.
  • The quoting and invoicing systems for accountability to track government sales differ from the internal systems used for channel partners.  These issues surface the first time a manufacturer must participate in a Contractor Assessment with a GSA Industrial Operational Analyst (IOA).
  • The mindset of selling direct from the manufacturer doesn’t provide a government customer with the technical support, integration services, or value-added experience which comes from an authorized VAR/dealer. 
  • Manufacturers must update their own MAS GSA contracts with contractual modifications through GSA.  Price increases, new products, discontinued items all must be continually updated requiring the manufacturer to understand this process or hire a consultant.  And they must rely on their channel partners to update the manufacturers prices and product offerings on their respective GSA MAS contracts.

Option 2: Only the Manufacturer Holds a GSA MAS Contract

Let’s look at a situation where a large manufacturer works with hundreds of VARs/dealers throughout the country.  Under this option, the manufacturer could benefit from authorizing VARs/dealers to use their GSA MAS Contract.  No letter of supply from the manufacturer is required.

Effectively, the manufacturer grants permission to a VAR/dealer through a modification to the manufacturer’s GSA MAS Contract.  That VAR/dealer can then ‘reference’ the manufacturer’s contract number for all sales to a government customer.  The VAR/dealer may have their own GSA MAS contract respectively, but they will not be authorized to resell this manufacturer’s items on their contract.

Things to consider with this option of only the manufacturer holding a GSA MAS Contract:

  • The manufacturer maintains control of the contract, pricing and the sale of their products through the MAS GSA contract.
  • This option requires an organized and well managed approach to ensure that both parties (manufacturer and VAR/dealer) understand how to quote, invoice, track and report sales as well as pay the Industrial Funding Fee (IFF). 
  • All VARs/dealers should sign an agreement with the manufacturer which outlines the terms and conditions of using the manufacturer’s GSA MAS contract.  Having a turn-key approach to making this option work is important so nothing falls through the cracks from a compliance standpoint. 
  • Manufacturer must have a dedicated contract administration individual(s) to ensure all administrative, maintenance and compliance contract items are satisfied for the contract.
  • As mentioned in Option 1, the manufacturer will still need to set up quoting and invoicing systems for accountability to track government sales through their GSA contract separate from all other sales.
  • The manufacturer will still have to update their own MAS GSA contract with contractual modifications through GSA.  Price increases, new products, discontinued items must be continually updated requiring the manufacturer to understand this process or hire a consultant.

Option 3:  Manufacturer Encourages a Select Group of Channel Partners to Get a GSA Contract

The final option consists of a more forward-thinking approach to leveraging the GSA MAS Contract with the least number of changes required to the business model of a manufacturer. 

Manufacturers should consider encouraging a select group of authorized resellers in their government market base to pursue qualifying for a MAS GSA Contract.  Select these candidates based on their performance, geographic coverage, or commitment to the manufacturer’s product and the value delivered to the end customer. 

The manufacturer may even elect to share in the cost of the authorized reseller obtaining a GSA MAS Contract with an experienced consulting firm.  The benefits from this option far outweigh those delivered under Options 1 and 2 for the manufacturer, including:

  • Manufacturer selects group of authorized VARs/Resellers and provides a LOS only to these partners for obtaining a MAS GSA contract.
  • Manufacturer is not required to quote, invoice, track or report sales or pay an IFF.
  • All contract administration, maintenance and compliance are the responsibility of the authorized reseller holding the MAS GSA contract.
  • Manufacturer provides updates to products and pricing directly to their authorized VARs/Resellers.   The channel partners take care of all contractual modifications to bring their MAS GSA contract up to date.

If you have any questions or would like to further discuss this topic, please reach out to us at info@clearcoastusa.com.  The content provided herein comes from over three decades of experience of working with manufacturers and their channel partners relative to the GSA MAS contract program.

Help! My Costs Have Increased

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Are you feeling the pain of increased costs to your business? If you are like most of our government customers, your business is feeling the brunt of the rising costs of goods and services, and so too are agencies and their ability to meet their missions.

GSA Tackling Challenge to Reduce Heavy Burden on Contractors

Not since the mid-1970s have we experienced such an inflationary crunch placing a heavy burden on contractors and their supply chains, especially small business contractors.

The good news is that GSA has recognized the inflation challenge and is trying to do something about it to keep contractors from leaving the government market altogether, in part, because they are losing money.

GSA released Memorandum Acquisition Letter MV-22-02 on 3/17/2022 to provide a temporary moratorium on the enforcement of several limitations contained in certain GSA Economic Price Adjustment (EPA) clauses.

Effectively, the Acquisition Letter from Jeff Koses, Senior Procurement Executive:

1. Lowers the approval for price increases above the EPA clause ceiling in 552.216-70, from the contracting director to one level above the contracting officer.

2. Relaxes time limitations on EPA increases.

3. Relaxes limitations on the number of EPA increases a contractor may request.

4. Clarifies that if a contractor has removed an item from their Schedule contract, GSA will not enforce the limitation on adding the same item back at a higher price.

What does this mean for you as a GSA Contract holder? If your costs have increased as a channel partner in which the manufacturer has increased your pricing or you are a business reliant on maintaining a highly qualified labor market and your costs have skyrocketed, you can seek to increase your pricing. Typically, EPA requests could not exceed the allowable ceiling limits of 10% for products and 5% for services per GSA clauses GSAR 552.216-70 – Economic Price Adjustment and I-FSS-969, Economic Price Adjustment.

Come Prepared to Justify Price Increases

At ClearCoast, we have prepared dozens of EPA requests over the last 3 months for customers.  From manufacturers and their channel partners to businesses offering professional services, software, or other tools, we have guided customers in providing the proper documentation for consideration of an EPA by their contract officer.

For example, documentation from manufacturers could include the freight and fuel charges of raw materials and how it effects your supply chain. National industry resources publish statistics or cost indexes of what is happening based on the economy. GSA contractors should gather that data and any other supporting information to justify what is happening and tell the whole story.

Many companies have experience increased costs to their labor categories as employees return to work. These costs funnel down to a business’ bottom line, so it is important that you show the contract officer the data to enable evaluation of an EPA.

GSA is Stepping Up to Help Contractors

Acquisition Letter MV-22-02 outlines the actions as deemed necessary for GSA Contracting Officers to take in support of EPA requests from contractors including:

  1. Conducting a thorough evaluation, according to applicable policies and procedures.
  2. Approving EPA requests for increases that exceed the ceiling established in the solicitation with approval one level above the Contracting Officer.
  3. Taking into consideration all supporting data provided to show the impact to a GSA contractor’s bottom line.

This Letter and the actions outlined are in effect until September 30, 2022, unless otherwise extended.

ClearCoast recommends that GSA Contractors consider acting now to address the inflationary costs that have impacted their GSA Contract pricing. Don’t wait until it’s too late.  

If you have any questions or would like to discuss how we can help you increase your GSA prices during these challenging economic times, please contact us at info@clearcoastusa.com

Security Integrator Supports Local Community During COVID through GSA MAS Contract

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Reprinted with permission from ICU Technologies, a ClearCoast client. This blog post was originally posted by Team ICU on Jul 9, 2020 9:26:30 AM.

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Lake Tahoe Community College’s (LTCC’s) leadership recently executed a plan to provide the community with a COVID Surge overflow hospital but transitioned to being one of only two COVID testing facilities in El Dorado County. Here is how it happened:

LTCC’s Superintendent/President, Jeff DeFranco was quick to recognize the challenges posed by the COVID crisis. Anticipating the need to support the Lake Tahoe community, DeFranco agreed to use part of the LTCC campus as an overflow hospital in the event the local hospital was overwhelmed with patients. Thankfully, the community was quick to protect themselves against the virus and a hospital surge location was not necessary. The work to prepare for hospital overflow, however, was not wasted. A new need arose – finding a suitable COVID testing facility.

LTCC’s Al Frangione, who oversees the college’s facilities and security, was assigned as the Incident Commander for the college. Frangione explained that DeFranco was “all in, to make sure the hospital overflow concept was a success.”  Frangione quickly went to work, defining the necessary space, people, and materials. Frangione explained:

“One key component which is evident in any healthcare setting is security. Access control coupled with video monitoring of access points, perimeter and common spaces is a core responsibility which cannot be overlooked.”

Frangione reached out to ICU Technologies, LTCC’s preferred security integrator, to get an initial design. He explained, “I’ve worked with ICU in the past and am familiar with their GSA/CMAS contract process which cuts through the red tape and makes purchasing and installation as streamlined as possible — especially in an emergency.” He added, “In uncertain times, some companies might up their pricing, but partnering with companies like ICU, which are GSA/CMAS contract holders, protects us as the pricing schedule is in place prior to the emergency and has been approved as being legal, reasonable, and competitive.” An initial assessment led to a decision to install nine public safety cameras and electronic access control to monitor doors at the exterior entrances.

Within a few weeks, the fears about patient overload passed and El Dorado County officials recognized the need for a suitable testing location. Frangione explained, “Since Lake Tahoe Community College was mission-ready, we were selected as one of two county facilities for this critically important work.” The testing location required high levels of security for patients, testing staff, equipment, and to effectively control the security of the samples themselves. To date, 2,800 people have been tested. Details about testing can be found at: https://www.edcgov.us/Government/hhsa/Pages/EDCCOVID-19-Get-A-Test.aspx

ICU’s CEO, Brian Van Norman, said, “we’re happy to support LTCC in this critically important public health undertaking.” He added, “We applaud LTCC Superintendent/President Jeff Defranco’s vision and forward-thinking response.” Van Norman continued by explaining, “We are proud our company has the ability to quickly respond to meet community needs through our well established industry relationships, with manufacturer partners like Motorola-Avigilon, and our large subcontractor network that spans the Western States.”

Public sector leaders with security related issues should contact ICU Technologies at: icu-techinc.com

Opportunities for GSA MAS Contractors in the Time of COVID-19

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President Donald Trump signed into law Friday afternoon, March 27, 2020 a historic $2 trillion stimulus package as the American public and the US economy fight the devastating spread of COVID-19.

The far-reaching legislation stands as the largest emergency aid package in US history. The $2 trillion federal stimulus bill also includes $340 billion (in addition to the $150 billion) in emergency supplemental funding of which more than 80 percent ($274 billion) will go directly to states and localities, according to the Senate Appropriations Committee.

Here is a breakdown of some of the key funding streams that are either directly related to technology or may incorporate technology as an allowable expense:

  • $400 million for elections security
  • $25 million for distance learning, telemedicine and broadband for rural communities
  • $850 million to states and localities through the Justice Assistance Grant (JAG) for public safety and criminal justice agencies
  • $200 million for telehealth for the FCC to support healthcare providers
  • $9.1 million to protect critical infrastructure from Department of Homeland Security
  • $500 million for public health data surveillance and infrastructure modernization for state and local public health
  • $1.5 billion in state and local preparedness grants from FEMA
  • $13.5 billion in formula funding for K-12 districts to meet immediate needs and improve use of ed tech $5 billion in Community Development Block Grants (CDBG) to provide states and localities with the resources to serve their constituents
  • $4 billion in homeless assistance grants to address the homeless population during COVID-19
  • $1.5 billion in grants for economic development for communities suffering due to COVID-19

What does this mean for government contractors?

It means opportunities. Plain and simple. Government contractors are playing and will continue to play a critical role in supporting government decision makers with their immediate, near-term and long-term response requirements.

As a result of COVID-19, federal and state governments have a sudden and unanticipated need for more goods and services.  Some of those goods and services are highly specialized and specific to COVID-19.  FEMA has published a list of Personal Protective Equipment (PPE) and critical supplies needed at this time along with their contact information.

But governments also have an increased and urgent need to buy otherwise-routine goods and services that have become newly critical in the wake of COVID-19.

All of this means that there are and will be procurements where speed is the priority, and where there is no time for the normal pace and cadence of the procurement process and contract formation.  It also means that resources necessarily will get taken away from routine procurement tasks and reallocated to urgent matters.

If you are a GSA Multiple Award Schedule (MAS) holder this is great news as you are eligible to provide needed supplies and services to State and Local agencies during this crisis. The GSA MAS is specifically designed to address emergencies and government leaders are being encouraged to work with pre-approved vendors through the GSA MAS Disaster and Recovery Program. Purchase thresholds have even been increased to allow for greater and immediate procurement flexibility.

Be a Strategic Partner and Problem Solver.

This is not the time for cold calls. C-level government decision makers need trusted partners and proven solutions which can address their immediate needs including:

  • Rapidly deploying telework and remote work for state and local agencies
  • Securing this new mobile workforce and protecting existing assets
  • Expanding the number of digital services to serve constituents and businesses
  • Everything that directly supports the COVID-19 response

Technology is playing a critical role in the coordination and response of state and local government agencies to COVID-19. Get with your government customers. Ask them how you can help. Tell them you are a GSA MAS contract holder. And then muster your resources, creativity and solutions to be a leader during this time of crisis.

Things are moving fast. We will continue to monitor as best we can and keep you updated.

Other Helpful Resources for Greater Insight

GSA, GSA MAS, GSA News, News

GSA Multiple Award Schedule (MAS) Consolidation: Are You Prepared?

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On October 1, 2019 GSA released the new Consolidated Multiple Award Schedule (MAS) Solicitation designed to replace the current structure of the GSA Schedules program. By consolidating the existing 24 individual schedules into one Schedule, GSA will eliminate the need for industry to deal with multiple schedules contracts, multiple contracting officers and multiple sets of terms and conditions. This initiative is part of the continued effort by the federal government to streamline the acquisition of products and services.

This is excellent news for government and industry alike. However, as an existing or new GSA contract holder are you ready?

ClearCoast, with 30+ years government acquisition experience, has helped hundreds of clients secure and maintain their GSA Schedule contracts.  We now stand ready to assist you in this transition process in which GSA has consolidated 24 GSA Contracts into a new Consolidated MAS consisting of 12 large categories (see below), 83 subcategories and 316 Special Item Numbers (SINs) which now closely align to the North American Industry Classification (NAICS) codes.

What do I need to do to prepare for this transition?

GSA is implementing this Consolidation in three Phases. ClearCoast has highlighted action items for new and existing GSA Contractors to address during each phase.

Phase 1 (2019 – January 2020) – This was the largest phase and is now complete. GSA reviewed all terms and conditions across schedules, isolating the terms and conditions for all vendors and what were very specific to a category or subcategory. Also reviewed was SIN duplication and overlap. The result was deletion of 160 clauses and a reduction of 900 legacy SINs to 300 SINs now mapped to NAICS codes. It’s important to note that the VA Schedules were not part of this consolidated initiative to modernize federal acquisition into a single GSA Schedule.

ACTION ITEMS:

New Contractors: If seeking to submit an offer for the new Consolidated MAS contract you must apply based on the solicitation requirements released on October 1, 2019. Please see the following link for a roadmap of what is required to prepare for your submission.

www.gsa.gov/mascategoryrequirements

Existing Contractors: Now is the time to address housekeeping items related to your current contract before GSA issues a mass modification Refresh #1 (end of January 2020) for accepting the new requirements for the Consolidated MAS. Your contract number will not change but there will be changes to your SINs. GSA will now reference your schedule based on the large categories as listed above and will not refer to the Schedules by number (i.e., Schedule 70, Schedule 84, etc.) going forward.

To prepare for this mass modification in 2 weeks:

  • Close out all outstanding mass modifications
  • Submit and finalize any e-mods before accepting the Refresh #1 mass mod
  • Current SAM system is migrating to beta.SAM. Create a new user account at https://beta.sam.gov/. Upon creating a new account you will be able to migrate existing SAM information to the new beta.SAM.
  • Ensure your NAICS codes are all updated. GSA will use the preponderance NAICS code to determine your size status on the new consolidated contract.
  • Begin to update your current text file to change legacy SINs to new SINs (ClearCoast can help you map your legacy SINs to the new SINs to update your text file). Upon acceptance of the Refresh #1 mass mod it will then be uploaded to elibrary.
  • Review changes to the Maximum Order Threshold to determine impact to your new SINs (ClearCoast can assist you with this determination)

Phase 2 (Feb – July) GSA will issue a mass modification Refresh #1 at the end of January 2020 to all existing vendors holding a single GSA schedule contract.  This Mass Mod will migrate contractors to the new terms and conditions under their new Consolidated MAS contract, keeping the same contract number, existing task orders and BPA’s.  Contractors will have until July 31, 2020 to accept this mass mod.

ACTION ITEMS:

  1. Prior to accepting this mass mod, existing contractors should ensure that all action items listed in Phase I are complete. In addition, if an e-mod to add a NEW SIN under the legacy SINs was submitted in January, existing contractors should wait until that modification is approved prior to signing the mass modification.
  2. When responding to the mass mod, you will be presented with each clause in the consolidated Schedule and will be able to either accept the clause or request an exception to the clause. So it’s important to read through the Mass Mod in detail.
  3. GSA will be conducting online training for mass mod Refresh #1 so look for the announcement to your email box.
  4. If you have not done so, be sure to join GSA Interact for all the latest information, training sessions and helpful guidance related to the Consolidated MAS  https://interact.gsa.gov/
  5. GSA will be taking care of the eMod, eBuy, eLibrary, SIP and GSA Advantage systems to ensure that after acceptance of the mass mod Refresh #1 all legacy SINs will be converted to the new SINs for existing GSA Contractors within these online systems.

Phase 2 (March-April) – For GSA vendors seeking to add SINs that were previously on separate schedules, GSA will accept eMods for this request. For example, a contractor under the Information Technology Category may seek to add SINs under the Security and Protection category to offer a more comprehensive solution to their customers.

Phase 3 (July – November) – The GSA FAS Program Management Office (PMO) will begin working with those contractors that hold multiple schedule vehicles. The PMO will initiate the consolidation of these schedules by sending an email to set a one-on-one meeting to discuss contractor objectives and develop a consolidation plan. This process will be in accordance with the number of schedules vehicles involved and where those schedules are in their life cycle.  Once this plan is developed the contractor and, if needed the PMO, will communicate with all GSA Contracting personnel to accomplish the consolidation.

ACTION ITEMS:

Existing Contractors: If you are an existing contractor holding multiple schedules be sure to bring all schedules up to date via eMod. Decide which contract makes up the greatest portion of sales which will become the primary contract. GSA will then migrate all other contracts to this primary contract and cancel the others through a formal modification. All discounts will be maintained during the migration process. The PCO for your new single contract will receive copies of all contract mods for the contract to be maintained going forward.

What impact will the Consolidated MAS Contract have to the TDR Reporting program?

If one item on your contract is currently classified as a TDR SIN then the entire contract becomes a TDR contract under the new Consolidated MAS Contract.

Will the Cooperative Purchasing Program open up under the new SINs?

At this time, the Cooperative Purchasing Program will apply only to those SINs offered through the Information Technology and Security and Protection categories (legacy Schedule 70 and Schedule 84).

For further information or clarifications, contact Denise Buczek at denise@clearcoastusa.com or at 310.633.7620.

View this blog as a PDF here.

Your GSA Contract Just Increased in Value!

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There are major changes happening at a higher level regarding helping the government buy smarter. The Office of Management and Budget’s (OMB) new policy memo on Category Management makes it an integral part of the government for the foreseeable future. It’s a 30-page document which provides detailed instructions/requirements for agencies to move in this direction regarding all future purchasing to increase efficiency, reduce costs, minimize redundancies and deliver more value.

What does this mean to you?

Your GSA Schedule contract just increased in value! In a nutshell, category management includes a classification system of “Best In Class” (BIC) contract vehicles which agencies will be directed to use for all product/service procurements. The GSA Schedules program is already approved as a Tier 2 BIC contract vehicle. This gives extra credibility and weighted value to this procurement vehicle. When a contracting officer is presented with a choice of a multitude of vehicles and they are now mandated to use a BIC vehicle – your GSA contract becomes more relevant as the chosen path.

OMB is working to educate agencies and your customers on this new policy for making purchases. Your sales team should use the slip sheet below with customers to make them aware of this initiative and to spread the word. It’s another way to promote your GSA Schedule contract as the preferred choice for government customers to buy from you.

Download slip sheet

GSA Schedule Holder – Are You an OLM Participant?

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If you are a GSA Schedule holder and are not familiar with the term OLM ‘Order Level Materials’ – you need to be!

GSA, as part of their efforts to deliver best value commercial solutions to government agencies through the GSA Multiple Award Schedule (MAS) program enacted the OLM rule earlier this year. It’s one of many initiatives that GSA is undertaking to bring flexibility to government buyers, streamline the procurement process, expand business opportunities for schedule holders and promote innovation.

What are OLMs?

  • Supplies or services acquired in direct support of task or delivery order placed against a Schedule contract or Blanket Purchase Agreements (BPAs) (no more than 33.33% of the order, excluding travel costs).
  • The type and quantity of supplies or services are not known at the time of Schedule contract or BPA award.
  • Prices of OLMs are not established at the Schedule contract or BPA level.

OLMs are a game changer for all! There are numerous benefits to both the Schedule contract holders (Industry Partners) and the customer ordering agencies.

Benefits to Contract Holders and Customer Agencies

GSA has created flexibility for Schedule Contract holders by allowing the sale of supplies and or services not approved on the contract. This opens doors to compete for more orders and removes entry barriers to the marketplace, particularly for small businesses. Now you can offer a comprehensive listing of products and services without having to go through a formal ‘add’ modification process to your contract.

For customer agencies, OLMs reduce administrative and transaction costs relative to contract duplication and the need for additional contracts for ancillary work respectively. Ordering agencies still have to make a fair and reasonable price determination for all OLMs but its accomplished through a more effective and streamlined approval process.

In adding this capability to the schedule contracts, OLMs not only improve the ability to position the Schedules as the commercial, best value contract vehicle; it also has a great impact across the entire MAS program to deliver best value to the American people. For schedule holders and customer agencies alike, this is a win-win proposition.

Implementing OLMs – Get Up to Speed

As you prepare for 2019, now is the time to get up to speed on the mechanisms that will benefit your bottom line and save time and money. OLMs are one such step forward for GSA and Industry Partners. There are guidelines associated with OLM participation with which you should be familiar. Please take the time to attend a GSA offered webinar or visit their website for more information.

GSA is offering a webinar on December 20, 2018 from 10:00pm-12:00pm EST titled, “GSA/FAS Order Level Materials (OLM) Briefing for Industry Partners”. This session will provide training on the new Order Level Materials GSAR rule. For webinar details click here.

In addition, you can visit GSA’s Order-Level Materials home page at www.gsa.gov/olm  for ‘Frequently Asked Questions’ and the most up-to-date information on this initiative.

Still have questions?  We’re here to help. Please contact us at denise@clearcoastusa.com.

GSA Introduces New CALC Tool: Accurate or Subjective Pricing Data?

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The General Services Administration has launched a new tool to make it easier for agencies to figure out the hourly rates for various labor categories. But, what does this really mean to contractors?

The Contract Awarded Labor Category (CALC) tool allows contracting officers to conduct market research and price analysis across awarded prices on 48,000 labor categories from more than 5,000 recent GSA contracts.

Need to know the hourly rate for a financial analyst with a bachelor’s degree and five years of experience? Or a lab director with a Masters degree and 10 years of experience? The CALC tool cuts down on time and effort by helping contracting officers crunch the data instead of having to comb through contract data by hand, according to GSA.

CALC currently searches the awarded prices on several of GSA’s professional services schedules, including Mission Oriented Business Integrated Services (MOBIS), Environmental, Logistics Worldwide (LOGWORLD), Professional Engineering Schedule, Language, Advertising and Integrated Marketing Schedules (AIMS), and the Consolidated Schedule.

For contractors who currently seek to qualify for a GSA Schedule, submit modifications for price increases, add new labor categories or bid on service contracts, this makes the process a bit more subjective and murkier.

Price comparisons based on a title, years of experience and education vary from one company to another. It’s never an apples to apples comparison and strikes at the heart of the GSA Schedules program which was formed based on evaluating a company’s individual commercial practices. Leveling the playing field through price comparisons of the masses vs. assessment of individual vendor performance hurts and chases away top-quality vendors from competing and working with federal customers.

According to developer, 18F, future versions of the CALC tool are likely to include the ability to input a proposed price for a particular labor category to see where it falls against comparable awarded rates, as well as additional ways to control and visualize the labor data.

From our perspective, it remains to be seen if the CALC tool can evolve with algorithms which take into account the ‘intangible’ things that go into pricing for services by vendors.

For more information on how ClearCoast can assist you with your government contracting needs, please contact us at info@clearcoastusa.com.

New Changes for GSA CAV’s

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GSA is once again making changes to a core element of its administration of Multiple Award Schedules (MAS) Contracts & the Contractor Assistance Visit (CAV). The term Contractor Assistance Visit (CAV) will no longer exist.

These CAV reviews will be called “Assessments” going forward. Not only has there been a name change but the frequency of the assessment based on various contract factors including sales volume, sales adjustments previous assessments, etc has also changed.

Traditionally, GSA contractors received two Contractor Assistance Visits (CAV) during a five-year period. For contractors who are compliant with the terms and conditions of their contract including sales reporting and Industrial Funding Fee (IFF) payment and have annual sales less than $150,000, an “Assessment” will be conducted once per five-year period, most likely in year four. For GSA contractors with annual sales greater than $150,000, an annual Assessment will be conducted. The format in which these Assessments will be conducted will be in-person or virtual.

The Assessments will still focus on the full compliance review areas experienced by GSA contractors today (Scope, IFF payments, prompt payment terms, GSA Advantage! Price Lists, Basis of Award (BOA), Discounting, etc.) However, the MAS report card will disappear by the end of FY2015 and while a report will be issued by the Industrial Operational Analyst (IOA) conducting the assessment, it will not be ratings based. The Assessment Report will be made available to the GSA Contractor and their Contracting Officer (CO).

In March 2014, the responsibilities of the IOAs changed to a more administrative support role for GSA Schedule holders. The IOAs assumed all non-contracting responsibilities regarding sales reporting and the Industrial Funding Fee (IFF) matters. The IOA assigned to your contract assists your company with all questions and transactions regarding sales and IFF. GSA now has an IOA locator posted on their Vendor Support Center website to help identify the IOA assigned to your contract.

As a result of the IOAs new roles, the frequency of Contractor Assistance Visits (CAV) will change. Traditionally, Contractors received two Contractor Assistance Visits (CAV) during a five-year period. In the near future, the frequency of the assessment will now depend on various contract factors, such as sales volume, sales adjustments, previous assessments, etc. GSA believes these changes will result in greater efficiency and effectiveness.

GSA is operating in a time of significant change, one that is being driven by the fiscal realities of government wide spending cuts. In 2013, the Federal Acquisition Services (FAS) reviewed the Supplier Management Division’s contract administration functions. As a result, an internal realignment of resources continues to evolve. The implementation of the CAV changes began in February 2015, and the General Services Administration’s (GSA) goal is to have them fully implemented by the end of FY 2015.

For more information on how ClearCoast can assist with your GSA Schedules needs, please contact us at info@clearcoastusa.com.