SPEL – The New GSS Modification Process

Over the years GSA has had issues with getting GSA Modifications awarded in a timely manner. To facilitate processing times, the Office of General Supplies and Services (GSS) has created the Standardized Pricing Evaluation Logic (SPEL) tool. These changes are applicable only to Economic Price Adjustments (EPA) and product addition modifications. Contractors currently enrolled in Transactional Data Reporting (TDR) are already required to use the new MOD process.

What is SPEL?

Standardized Pricing Evaluation Logic, also known as SPEL, is the new GSS modification process. GSA, in conjunction with the OIG, has developed an algorithm to review and assess modifications requests against existing products, commercial market, past transactions, non-selling products. The result is a spreadsheet of acceptable products and rejected items with explanation.

Why is GSA Changing the Mod Process?

GSS has done extensive research and upgraded their algorithms to include TDR, Commercial, and Consumer Price Index data, that they can automatically recommend approval for legitimate price offers compared to recent GSA 4P tool evaluations. This new mod process also improves their control of overpriced items. With that said they have found that a higher percentage of pricing approvals was recommended by SPEL than 4P. This resulted in thousands of additional contracts offers being eligible for award. Because of this logic the Contracting Officers are now required to follow this new process.

This will result in faster modification approvals, but also many more modification submissions as contractors will need to adjust pricing and resubmit to get the rejected items added or increased. The SPEL process does not appear to allow for clarifications or negotiations. Coley’s contract managers are specialized in ensuring that all of our clients contracts have accurate and competitive pricing in order to maintain our 100% awarded rating for all submitted contracts.

How does the new EPA MOD with SPEL work, according to GSA?

1. Run the mod Price Point Plus Portal (4P) output through the new SPEL tool to maximize the number of legitimate offer prices GSA can automatically approve while also improving controls on “unreasonably” high prices.
2. Contractors must then submit a clean Product Pricing Template (PPT) file with only the items where the price has been deemed acceptable. This will be immediately processed to update contract offerings as soon as possible. Processing these “clean PPTs” has thus far resulted in successful catalog updates within just a few days.
3. For items where pricing was rejected, the contractor has the choice to reduce pricing and resubmit on a separate modification. Approval cannot be guaranteed in advance, as offer evaluation is based on market data at the time of resubmission, but a “Target Price” is provided to contractors as a helpful indicator of potentially competitive pricing.
4. For items where “No Market Research” is found, the contractor must take several factors into consideration:

Key Considerations

1. The contractor should consider which items have a legitimate expectation of significant demand before including them on a new PPT. Outside of data-matching issues, actively selling items should not result in “no market data found” on an offer. If the item is an active-seller and the contractor believes that “no market data found” was due to a data matching issue, then the contractor should validate the item information on the PPT and resubmit with the justification “Suspected Data Matching Error.”
2. While GSS understands the need to offer items in support of prospective sales, there is a cost to GSA to validate and maintain bloated catalogs with tens of millions of items that will never sell. As a result, a new requirement of this program is that, when re-submitting items with “no market data found,” a justification of why existing or potential sales should be expected for each item will be required. They will evaluate these justifications and refine this requirement as they gather intelligence from our industry partners.
3. As Supply Chain Risk factors such as country of origin cannot be systematically determined for these items, item-level attestation will be required for all “No Market Data” items submitted.
4. The revised policy for pricing evaluation for items with “No Market Data” is still in development so the Contracting Officers are currently directed at evaluating pricing consistent with their past practices. As a result, pricing evaluation for these items will take much longer than it will for items that do have market data. As this part of the process is largely unchanged, these items are not expected to take any longer to evaluate and approve than what contractors experienced prior to SPEL implementation.

Coley GCS supports and encourages our clients to complete modification(s) following the appropriate processes and helping them stay competitive. If you need help with an EPA or addition modification on GSA, you can be sure that, with Coley, the processes are always followed and that all GSA Schedule offerings and price lists are up to date.

Coley has over 20 years’ experience helping Clients obtain and maintain their GSA Schedule. We are available to help make the process easy. Contact us today at hello@coleygsa.com, by phone at 210-402-6766 or schedule a call to get started on obtaining your GSA Schedule—a critical step on your road to success in the government market.