New Consolidated  Multiple Award Schedule Coming Soon & GSA wants Your Feedback

New Consolidated Multiple Award Schedule Coming Soon & GSA wants Your Feedback

MAS Consolidation is happening as previously advised. Plans to consolidate all 24 GSA Federal Supply Schedules into one mega schedule beginning October 1, 2019. GSA has released an industry Request for Information on changes and formatting to the new solicitation scheduled to arrive in the next fiscal year: (more…)

Can You Decline GSA Schedule Orders?

Can You Decline GSA Schedule Orders?

A new email pops into your Inbox. It’s an order off through your GSA schedule directly through GSAAdvantage. Your first thought is elation – the schedule program is working!

2019 NDAA Restricts Government Use of LPTA

2019 NDAA Restricts Government Use of LPTA

Federal professional services firms should all breath a sign of relief— one of the many changes of the FY2019 National Defense Authorization Act (NDAA) is the government-wide restriction on the application of Lowest-Priced Technically Acceptable (LPTA) as the basis of award on complex professional and IT services contracts. (more…)

Prepare For the New FAS Sales Reporting System

Prepare For the New FAS Sales Reporting System

72A to be Terminated This Year

(May 20, 2019 Update:  Register For the New FAS Sales Reporting System)

As many GSA Schedule contractors are aware by now, GSA will be retiring the 72a Sales Reporting System and will require current users to make a switch to the new FAS Sales Reporting Portal (SRP).  72a is currently being described by GSA as a “legacy” system and will be terminated later this year.

You may have received correspondence from GSA earlier this year about the upcoming transition, however it did not specify the most important questions: when exactly will the transfer occur, how will this be done, and who will have access?

As of yesterday, many contractors are reporting about very specific instruction received regarding the
transition.  All questions have been answered and many concerns have been alleviated.

If you are currently using 72a as the platform to report sales, it is likely this April will be the last time you will be use this legacy system.  For this reporting quarter continue using your standard process: gather your sales by Special Item Numbers awarded against your contract and report via 72a as you normally would.  If you have generated any IFF (Industrial Funding Fee), continue to process payment via 72a as well.  Finally, say farewell to 72a as this would be the last time your going to be using this system.

Mark your calendars!  Sometime in May of this year, you will be able to set up your new FAS SRP
account.  Authorized Negotiators, Contract Administrators, and the listed IFF Representative on your contract will all be able to register.  Be advised that
this system will have implemented GSA’s improved security enhancements
and will not require the use of digital certificates,
however will still be used when submitting modifications and offers to GSA.

After the FAS SRP has been properly set up, your next sales report and IFF remittance will be completed within the FAS SRP for the APR-JUN 2019 quarter.  Sometime after, your historical records will also be migrated from legacy to SRP.

Don’t wait until the next SRP update from GSA!  There are actions that you can do now to help ensure a successful transition to the new sales portal.  We strongly suggest that you review your contracts’ listed points of contact and ensure that all contacts have valid contact information.  If something needs to be adjusted, or new points of contact need to be added, contact your Contracting Officer and submit your modifications now!

As always, we will strive to keep you up to date with the latest updates from GSA.  Please contact us if there’s anything that we can do to help via email or call us directly at 210-402-6766.

GSA Mass Modification for Order Level Materials is Coming

GSA Mass Modification for Order Level Materials is Coming

Beginning June 11-13, 2018; vendors should begin seeing mass modification invitations addressing Commercial Supplier Agreements (CSA)/End User License Agreements (EULA).

Following the acceptance of the first modification, vendors will see a second mass modification to add the Order Level Materials (OLM) SIN to select schedules. NOTE: The first modification regarding CSAs must be accepted before you are able to receive the OLM modification.

The OLM SIN will allow vendors to include supplies and services necessary to perform a job when supplies and services are not known at the time. Items placed under the OLM on task order are not awarded to your GSA schedule and pricing will be determined on an order level. OLM may only account for up to 33% of a total order.

This change will provide vendors flexibility in bidding opportunities and make GSA more attractive to agencies. OLMs also include the Industrial Funding Fee (IFF), so include fee when calculating costs. GSA will see an increase in revenue as a result, as well.

GSA has created a convenient chart to understand the differences between OLM and others:

The Affected GSA Schedules Include:

  • Schedule 03 FAC: Facilities Maintenance and Management
  • Schedule 56: Buildings and Building Materials/Industrial Services and Supplies
  • Schedule 70: General Purpose Information Technology Equipment, Software, and Services
  • Schedule 71: Furniture
  • Schedule 84: Total Solutions for Law Enforcement, Security, Facilities Management, Fire, Rescue, Clothing, Marine Craft, and Emergency/Disaster Response
  • Professional Services Schedule 00CORP: All Professional Services
  • Schedule 738X: Human Resources and EEO Service

If you have questions on the OLM or need assistance, contact Coley GCS at [email protected] or directly by phone at 210-402-6766

GSA Commercial Supplier Agreement Final Rule

GSA Commercial Supplier Agreement Final Rule

The terms & conditions of standard Commercial Supplier Agreements (CSA) have been a point of frustrated negotiations in federal procurement for years. GSA has tried numerous times to create “fail charts” of terms that are at odds with the requirements set by statute as well as in the Federal Acquisition Regulation (FAR).   (more…)

New Sick Leave Requirement for Federal Contractors

New Sick Leave Requirement for Federal Contractors

Executive Order 13706 – Paid Sick Leave for Workers on Federal Contracts

The Department of Labor released the latest Wage Determinations covering the Service Contract Act (SCA, now known as the Service Contract Labor Standards) July 25, 2017.  The wage determinations incorporate Executive Order 13706 – Paid Sick Leave for Workers on Federal Contracts, which requires all paid sick leave for all employees working on Federal contracts awarded after January 2, 2017.

The wage determinations did not include this provision until July 25th, so previous contracts incorporating the SCA will not be affected until the wage determination identified in the award or modifications are revised.

Here is what you need to know to be compliant with the new sick leave requirement:

  • All new contracts will be affected.
  • All non-exempt (SCA, DBA, or Fair Labor Standards Act) employees will accrue a minimum of 56 hours of sick leave annually
    • Contractor may make all 56 hours available immediately, or
    • Accrued at basis of 1 hour of sick leave for every 30 hours worked, at least to 56 hours annually.
  • Sick Leave requirement does not replace any portion of the Holiday & Vacation requirements
  • SCA employees must be notified in writing (pay stub) of their available balance every payday
  • Accrued sick pay does not need to be paid out on termination, unless employee is rehired within 12 months.
  • You may set a maximum of 56 hours to be carried over from year to year
  • Health & Welfare benefits are reduced from $4.41/hour to $4.13/hour

Covered employees can use sick leave for any of the following reasons and must provide “certification” from a health care provider for the absence. DOL defines certificate as “any type of written document created or signed by a health care provider (or by a representative of the health care provider) that contains information verifying the existence of the physical or mental illness, injury, medical condition, or need for diagnosis, care, or preventive care or other need for care:”

  • physical or mental illness, injury, or medical condition
  • obtaining diagnosis, care, or preventive care from a health care provider
  • caring for a child, parent, spouse, domestic partner, or any other individual related by blood or affinity whose close association with the employee is the equivalent of a family relationship who has any of the conditions or needs for diagnosis, care, or preventive care
  • as a result of domestic violence, sexual assault, or stalking,

If you have not modified your current GSA schedule to include the latest Executive Order, it is important that you begin that process. Coley GCS offers modification and consultation services, as well as training on the Service Contract Labor Standards.

For More information on the  New Sick Leave Requirement visit:

TAA Threshold Changes

TAA Threshold Changes

Effective January 24, 2018; DoD, GSA, and NASA issued a final rule amending the Trade Agreement Act Thresholds. The threshold establish trigger points as which each trade agreement becomes effective for federal acquisitions. However, Federal Supply Schedules (GSA), IDIQs, and other contract vehicles use the estimated contract values and therefore TAA nearly always applies. (more…)

Get Me Out of TDR!

Get Me Out of TDR!

If you were mandated to accept the Transactional Data Reporting provisions there is now a path to reverse to legacy clauses.

As stated by Mary Davie, Acting Deputy Commissioner of FAS, GSA has decided to make the Transactional Data Reporting (TDR) Pilot Program voluntary for those vendors initially included in the program. (more…)

Fixing Federal Verification Co., Inc. Mistakes on GSA

If your GSA contract was awarded using the debarred Federal Verification Co., Inc or one of their 40 plus aliases, your contract may be at risk of non-compliance.  Names used include GSA Applications, GSA 1000, GSA Processors, GSA Alliance, Federal Suppliers Guide, Government Awards Consulting, and a variety of others.  A list of Alternate Business Names appears here.

GSA debarred this GSA consultant and has requested all affected contractors to update their schedule to remove these consultants from your schedule.

To complete this process, you must have at least one digital certificate associated with a company representative with signature authority.  If you (more…)

CA, Inc. to Pay $45 Million for Alleged Noncompliance on GSA IT 70 Contract

Failure to comply with the False Claims Act has resulted in another large IT company, CA, Inc. paying $45 million in claims. The Department of Justice found that CA, Inc. neither disclosed all key commercial discounting practices nor offered them to GSA customers while negotiating its GSA Schedule contract.

The allegations against CA were brought to the Department of Justice through a whistleblower lawsuit filed by an employee of CA Software Israel, LTD; Dani Shemesh. The DOJ took the case over and pursued the claim.

CA, Inc. is resolving the allegations through a settlement; there has been no determination of liability.

The CA case highlights (more…)

Understanding the Impact of the new GSA Formatted Product Tool (FPT)

The General Services Administration (GSA) recently updated its regulations to implement the new Formatted Product Tool (FPT). FPT is a system upgrade to GSA’s eOffer/eMod system, that will replace the Schedule Input Program (SIP) and increase transparency around schedule contract pricing.

According to GSA, FPT will provide contractors with valuable information about their product’s pricing related to other vendors and provide contracting officers with data intelligence to use in price evaluations and negotiations. In other words, welcome to the era of undifferentiated, commodity-based pricing for everything, including Professional Services.

Vendors who currently hold  (more…)

GSA Transactional Data Reporting is Here, What it Means to You

On June 23, 2016, the General Services Administration (GSA) regulations to implement Transactional Data Reporting (TDR). The TDR Rule requires vendors to electronically report details, including the price, of all transactions processed through a GSA Acquisition vehicle.

Companies that currently hold or are in the process of obtaining one of the GSA Schedules listed below will be affected by TDR by the dates listed. While GSA eventually plans to apply the TDR program to all GSA Schedules, they are beginning with Schedules 72 and 58 I. A Solicitation refresh and Mass Modification will be issued for Schedules 72 and 58 I in about a week. (more…)

Price Reduction Clause Violations lead to Penalties

Deloitte to Pay $11M for Alleged False Claims/Price Reduction Clause Violation:

 Another example of the importance of compliance under the GSA Schedule contract. The GSA OIG (Office of Inspector General) issued a press release stating the Deloitte Consulting, LLP. Has agreed to pay $11.38 million for alleged false claims/price reduction clause violations.

The Department of Justice and GSA OIG handled the case and alleged that Deloitte failed to disclose more favorable pricing offered to a commercial customers and then did not reduce prices to Federal customer through their GSA schedule commensurately during the term of its GSA contract. Deloitte’s alleged failure to disclose and reduce GSA rates essentially resulted $11M in overcharges to Federal customers over the 6 years under suspicion.

Everyone in business wants to win work, and the Federal Government has been a consistent business partner and revenue source, but it comes with additional compliance costs. For government contractors, compliance and success in the Federal market go hand-in-hand. It is important to invest the resources into systems and processes that help ensure that compliance. Deloitte’s case is just one more in a long string False Claims or Price Reduction Act violations – most are too small to report. Here are some examples of the bigger ones:

  • Oracle did not fully disclose commercial sales practices and discounts and paid back $199.5 million in over charges.
  • An Office Furniture and products company did not monitor price/discount relationship and overcharged the government, paid back $9 million in over charges

Understanding the Price Reduction Clause Compliance to Avoid Fines

GSA, FAR, and ColeyGCS have training and service resources that can help your company understand the compliance concerns and systems required to remain compliant in Federal Contracting.

In our post How to Monitor Your Price Reduction Clause, we list out how to report deviations that disrupt discount relationships.

Get your GSA Schedule Pricing Relationship Right from the Start

If you’re considering a GSA schedule it is imperative that you get it right from the start. Take a deep dive into your current pricing practices and understand what mechanisms must be developed to ensure you remain agile and competitive commercially and compliant Federally.

At ColeyGCS, we perform an internal audit of our customers’ commercial practices before submission to identify standard practices and system to improve compliance.

If you have concerns about your compliance or simply are not sure one way or the other, please contact your GSA PCO, the VSC or contact ColeyGCS at 210-402-6766. We would be happy to help.

GSA Consulting Firm Debarred from Representing Vendors to the GSA

GSA Consulting Firm Debarred from Representing Vendors to the GSA

A Florida-based company, Federal Verification Co., Inc., that has done business under 68 different names, including GSA Application, GSA Processors, GSA 1000, GSA Preview, GSA Specialists, and Federal Suppliers Guide has been debarred (blacklisted) from working with GSA (see Excluded Parties List on

GSA recently notified all active and former clients of “GSA Processors, et. al.” that the company has been debarred following a formal agency protest from GSA and are no longer approved to represent vendors pursuing or modifying GSA Schedules. Vendors that have used “GSA Processors et. al.” have been ordered to remove them from their GSA Schedule.

Federal Verification Co., Inc. has been known in the industry as a “proposal mill” bilking thousands of companies using false guarantees of success and low pricing though telemarketers.  They have many complaints through the Florida District Attorney office and been discussed heavily in review sites such as ripoff report(more…)

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