On April 30, 2015, the General Services Administration (GSA) published Refresh 35 of the IT Schedule 70 Solicitation and Refresh 25 of the Schedule 84. The Refresh introduces significant changes that will affect contract vendors. GSA’s intentions are to increase the breadth of the competitive analysis and ultimately save taxpayers money by applying Universal Product Codes to all product offerings.
What’s Changing in the latest Refresh?
As of the date of the Refresh, all contractors are now required to submit Universal Product Codes (UPCs) for all items that are commercially available when presenting new offers or modifications.
Why the Change?
GSA has several objectives it wishes to achieve by introducing this Refresh. The stated purpose is to strengthen buyers’ means of locating and comparing items while reducing search result redundancies. By requiring more complete data, searching and comparing items gets significantly easier. It also makes it much simpler to be found on GSA Advantage. By improving a buyer’s search and compare capabilities, GSA hopes to facilitate increased competition.
Additionally, including UPC data bolsters the usefulness of GSA’s XSB Price Point software. Price Point is a powerful price analysis tool that GSA intends to use extensively when (a) determining fair and reasonable pricing – currently it uses Manufacturer Part Number (MPN) to perform this horizontal pricing analysis and (b) will allow Federal procurement officers access to the same information when performing their price analysis.
GSA will use this information establish competitive pricing amongst vendors and provide GSA leverage in rejecting or negotiations modifications and new offers.
They will also apply this information and Price Point system to the new Category Management program that will pull procurement information from across many Government contracting vehicles for comparison (e.g. GWACS, SEWP V, DoD eMall, OASIS, FSSI, OS3, ALLIANT, STARS, GSA, etc.)
The drum beat of “lower prices at all cost” that has been the mantra of GSA during the era of the Federal Strategic Sourcing Initiative (FSSI) has its detractors. Critics feel that tightening the purse strings through tools such as Price Point may further narrow already slim profit margins to the extent that they are unsustainable for all but the largest companies. This, of course, would have the effect of reducing competition and increasing barriers to entry.
I’m on the Affected Schedule, What do I need to do?
All current IT 70 and 84 schedule holders will be required during their next product modification to include UPC’s. If you are a reseller, you must contact your distributor or Manufacturer to obtain their UPC listing. If you are the Manufacturer and have UPCs assigned, you must now include those UPCs on the schedule items.
If you are a manufacturer or refurbish products and do not use UPCs, you must demonstrate to GSA that your company does not use UPCs commercially and provide an explanation. The GSA Procurement Contracting Officer has the discretion to determine if you can receive an exemption.
Taking these measures now will reduce delays or issues with future modifications.
This requirement will spread to cover all product offerings under all GSA schedules, as well as, other GWACs, Multiple Award Contracts and other channels.
Vice President for Coley GCS, LLC, a Government Contracts Consulting, Coaching and Training company. Daniel is a Certified Federal Contracts Manager (CFCM) and leads the day-to-day operations of Coley’s consulting practice. He has two decades of experience with the acquisition, management, and marketing of Federal, State, and Local government contracts. Daniel specializes in all aspects of GSA Schedules management and marketing and has helped hundreds of Coley clients remain compliant with the terms of their GSA contract while helping them expand their business.