CAV audit or meeting? Be Prepared.
Has it been close to 12 months since your contract has been awarded? Expect GSA to send an Industrial Operations Analyst (IOA) to visit and conduct and audit to your business either in person or virtually, this is called a Contractor Assistance Visit (CAV). The initial visit is more of an education and planning session to ensure you have the proper tracking systems in place. After the initial visit GSA will continue to visit every two years or so to conduct much more critical CAV audits which ensure your meeting the GSA Schedule compliance set forth during your award.
In a previous article, GSA Starting to Conduct Virtual Contractor Assistance Visits (CAV), we announced that as a part of GSA’s Strategic plan and making a diligent effort to provide federal savings and improve efficiency, IOA’s have steered towards conducting CAV audits virtually via teleconference versus sending an IOA to physically visit your business. However, since the announcement was publicized we have seen a fluctuating blend of both on-site and virtual visits.
Organize your Documents
We always stress the importance of maintaining an organized file of your contract documents. These documents should include your Standard Form 1449, Final Proposal Revision Letter (FPRL), most up-to-date CSP-1 disclosure, current GSA pricelist (updated in GSA Advantage!), and any modifications or SF30’s that have been awarded.
Prior to the actual CAV audit the IOA will request both GSA and commercial sales for the past year. The IOA will sift through the sales data and request to view invoices for the selected number of commercial and GSA sales. The IOA will analyze your invoices and schedule a visit for a time that best fits your team’s schedule to discuss the findings and ensure your meeting the compliance requirements. It is highly recommended to have key team members present during the audit whom are knowledgeable with the GSA contract, internal accounting system and sales history. The IOA will be looking for your best answers to the following questions, CAV questionnaire.
The most common issues identified during a CAV
- Outdated GSA Advantage! ® Pricelists/catalogs—upon modification awards you have 30 days to update GSA Advantage!® with your most up-to-date contract reflecting the changes.
- Under-reported/Over-reported sales—it’s crucial to properly, identify, track and report GSA sales accurately and completely.
- Commercial (MFC/BOA) Pricing compliance—contractors must maintain a system that monitors the Basis of Award customer discount relationship. GSA should receive the negotiated price or better without disrupting the discount relationship.
- Inaccurate GSA invoicing—contractors are required to display their GSA Contract number and prompt delivery terms (net 30, 2% 10 days, etc.) on their invoices or quotes. You should also be sure to notate the items which are not on your GSA Schedule and sold to your Federal customers as “Open Market” per line item.
- Inaccurate contact information –when changes occur internally such as address, email, point of contact, company change of name or novation. This must be promptly reported to GSA to initiate a modification.
Spend an adequate amount of time becoming organized and becoming prepared for your next CAV meeting—it’s an audit. The stakes are high and if any critical element is deficient your business could potentially result in adjustment of pricing, claims for recovering funds, or the cancellation or non-renewal of your GSA Schedule. You should learn from your mistakes during past CAV meetings and ensure all previous issues have been resolved for the next meeting.
Prior to your CAV meeting its recommended that you take a look at a sample of the Contractor Assessment Report that you will be issued after the assessment. The IOA will send a notification to the Contact for Contract administration and the Contracting Officer. If the IOA finds outstanding issues, then make this a high priority internally to correct the deficiencies.
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.