Does your proposal have an advantage over others?
Some clients that I have advised have benefited from utilizing the FAR 51.1, Contractor Use of Government Supply Sources during the proposal development process. FAR Part 51.1 includes a deviation which grants Federal Government Contracting Officers the authority to permit GSA vendors access to the Federal Supply Schedule (FSS), including those managed by the Department of Veterans Affairs, and GSA Global Supply Programs. The FAR 51 deviation can be used to your advantage on your next response/bid which will give you authorization to purchase available goods and services at GSA pricing to fulfill an agencies need. While doing your research to submit a bid, it is important to know who you can potentially purchase from if you win the award. As with any FAR Regulation, there are key characteristics that you should keep in mind when utilizing FAR 51.1.
- Items procured under FAR 51.1 must be placed on a time-and-material (T&M)/Labor-Hour (L/H) basis
- Ancillary Supplies/Services are acceptable items procured with FAR 51.1 so long as they are in support of the overall contract and are not the primary purpose of the work ordered.
- FAR 51.1 is limited to contracts/orders issued in accordance with FAR 8.450-1, Ordering Procedures for Supplies, and Services not Requiring a Statement of Work.
- State and Local Governments are not authorized by FAR 51.1.
After your contract manager has established that FAR 51.1 has been approved, he can ensure that the Contracting Officer provides you a Written Authorization for you to make available to other vendors when procuring items. In my experience, having this authorization at the time of award for my clients has helped avoid delays from vendors. Understandably, some vendors tend to have a degree of uncertainty on selling items to other vendors at GSA pricing, especially after the scam to GSA Schedule holders targeting Schedule 70 and Schedule 75. We recently published some tips on what to watch out to make sure you are dealing with a legitimate government customer. As a reminder, GSA released a list identifying Executive Agencies authorized to use GSA sources of supply and services. A list of the executive agencies can be found in our Who is Eligible to Purchase from My GSA Schedule? blog.
There are several benefits of utilizing the FAR 51 Deviation and if used properly, can give Small Businesses a greater competitive advantage over larger corporations with higher budgets. Leveraging the authorized GSA purchasing, Small Business can take to GSA Advantage! ® , identify other small business from whom to purchase at discounted pricing and provide a total solution for a government requirement. GSA has also provided the following benefits of utilizing the deviation:
- Allows GSA contractors to provide a total contract solution to meet customers’ needs.
- Expands upon existing benefits of GSA vehicles, such as streamlining of procurements, ease of ordering, leveraged pricing, time savings, and responsible contractors.
- Meets customer needs expeditiously because the ancillary supplies and services are readily available from the FSS Program or Global Supply Program.
- Reduces agency procurement and contract administration costs.
- Provides agencies opportunities to increase utilization of small businesses.
- Reduces the necessity for government furnished equipment (GFE), which is labor intensive to properly administer.
- Simplifies market research via existing GSA eTools.
- Encourages competition among contractors to seek the best solution, resulting in cost savings to the Government.
- Enables use of supply funds by contractors, which is the preferred payment method for some agencies
This entire process begins with the Federal Government issuing a solicitation that includes the deviation and begins receiving quotes and proposal. Once the proposals have been reviewed and a vendor identified, the contracting officer will issue the Authorization Template for you to provide to any prospective GSA vendors you will purchase from. It is important to remember that any services procured through a GSA schedule, the selling GSA vendor will have to report those sales as GSA and submit the IFF as usual. The purchasing vendor DOES NOT report these as GSA sales and DOES NOT pay IFF on these items as they are procuring these items on behalf of the government.
The following link is provided for additional information on the Policies and Procedures for FAR 51.1 – Contractor Use of Government Supply Sources.
Ramiro is a Certified Federal Contracts Manager (CFCM) and as a Senior Consultant with Coley Government Contract Services, he help clients with GSA schedule management services. He provides advice and ensures client’s GSA contracts are compliant and current.