I Have My Sales Data, Now What? Developing GSA Commercial Sales Practices Disclosures

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Darrell Dalton
6 years ago
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2 I Have My Sales Data, Now What? Developing GSA Commercial Sales Practices Disclosures Breakout Session #: E05 Jennifer Aubel and Barbara Connell Date: Tuesday, July 26 Time: 2:30pm 3:45pm

3 About Aronson LLC Aronson LLC provides a comprehensive platform of assurance, tax, and consulting solutions to today s most active industry sectors and successful individuals. For more than 50 years, we have purposefully expanded our service offerings and deepened our industry specialties to better serve the needs of our clients. From startup to exit, we help our clients maximize opportunity, minimize risk, and unlock their full potential. 2

4 About the Speakers Jennifer Aubel is a Principal Consultant at Aronson LLC. She is responsible for leading clients successfully through the GSA lifecycle -- from obtaining a new contract to managing ongoing contracts. She works closely with clients to custom-tailor solutions that meet organizational needs by developing scope and pricing strategies, maintaining contract compliance, providing OIG audit support, and improving the profitability and versatility of the GSA contract. Jennifer has nearly 20 years of experience in the federal market, working for contractors and as a consultant to GSA Schedule contract holders. Jennifer graduated summa cum laude from the University of Maryland University College with a bachelor s degree in Legal Studies. 3

About the Speakers Barbara Connell is a Senior Consultant at Aronson LLC where she works with government contractors to provide customized solutions that ensure success and compliance.

5 About the Speakers Barbara Connell is a Senior Consultant at Aronson LLC where she works with government contractors to provide customized solutions that ensure success and compliance. Barbara assists clients with GSA Schedule contract acquisition and management, Service Contract Labor Standards compliance, preparation of budgeted indirect rates and submission of incurred costs, and a variety of government contract compliance areas. As an expert in her field, Barbara is a regular contributor to Aronson's Fed Point blog and a featured speaker on Service Contract Labor Standards compliance. Barbara earned a bachelor's degree from the Pennsylvania State University, where she majored in marketing with a minor in information systems management. 4

6 AGENDA GSA s Commercial Sales Practices (CSP) Format Divide to Conquer Defining Standard and Non-Standard Practices Dealing with Outliers Unique Challenges with Services Tying it all Together 5

7 GSA S COMMERCIAL SALES PRACTICES (CSP) FORMAT 6

8 The CSP: Form and Function What is a commercial sale? Defining the universe for sales disclosures Excluding transactions from the sales data 7

9 The CSP: Form and Function Answering the Most Favored Customer (MFC) question Addressing reasons GSA may not receive MFC pricing 8

10 The CSP: Form and Function Disclosing standard sales practices Strategic alignment of GSA to a Basis of Award customer 9

11 The CSP: Form and Function Explaining non-standard sales practices Benefits of robust disclosures 10

12 Creating the Data Set Cover a recent 12-month period Include all proposed products and services Include zero-dollar transactions, credits and refunds Include relevant fields for sorting similar transactions (customer name, order #, list price, sale price, promo codes, date, etc.) Document exclusions 11

13 DIVIDE TO CONQUER 12

14 An Avalanche of Data Use existing sales policies to develop a basic context for the sales data Begin with the end in mind, but don t jump to conclusions about what the data mean Start peeling away groups of related data like the layers of an onion 13

15 Eating an Elephant The pricing analysis is much more manageable when you can break the data down into smaller bites Identify known customer categories or types of transactions: Classes of customers Promotions Subsets of products or services Specific product or labor category 14

16 Eating an Elephant Generally, sales data will have to be parsed several ways Making sense of it all will take time try not to get frustrated Tools like Pivot Tables and filters are invaluable in grouping and analyzing data 15

17 Pivot Table Exercise 16

18 DEFINING STANDARD AND NON-STANDARD PRACTICES 17

19 50 Shades of Grey There isn t always a bright line between standard and non-standard practices The less rigorous your pricing policies, the more ambiguity you are likely to encounter The more often a discount occurs, the harder it is to classify as non-standard Calculating the distribution of discounts can be a helpful exercise 18

20 Example: Distribution Analysis 19

21 The Kitchen Sink Approach Some contractors disclose every nonstandard practice they can think of, even if they don t do it The goal is to create blanket protection against triggering price reductions Many GSA contracting officers know about this technique, and it doesn t usually withstand OIG audit 20

22 DEALING WITH OUTLIERS 21

23 The Data Left Behind Once you have categorized your data, there is almost always some left that don t seem to fit Frequently, these transactions have discounts that are out-of-range Now it is time to do some detective work Reviewing the proposal, contract file, invoices, vendor history, etc. can be helpful in solving the mystery 22

24 What the Data Won t Say GSA defines a discount as any reduction to the effective price to the customer Terms and conditions and concessions can be difficult to capture from sales data Rebates, prompt payment terms, trade-in credits, etc. are all considered discounts Identify sources for such information 23

25 UNIQUE CHALLENGES WITH SERVICES 24

26 Square Peg, Round Hole Analysis of discounting really only makes sense based on a commercial pricelist Many service providers use market pricing and may have significant rate variability Mapping commercial labor categories to GSA positions is challenging Using a labor category matrix can be helpful for analyzing market pricing 25

27 Example: Labor Category Matrix 26

28 TYING IT ALL TOGETHER 27

29 Filling Out the CSP Beware of letting the format of the CSP drive your disclosures Add as much information as necessary to make sure the CSP is current, accurate and complete The greater the discount, the better the explanation of the practice should be The amount of the discount isn t always as important as its frequency 28

30 Strategic Considerations Desired Basis of Award (BOA) Explaining Non-Standard Discounts and Deviations Likelihood of Inspector General audit Proportion of GSA Schedule sales to overall commercial business Previous disclosures Working under legal privilege 29

31 Sample Disclosures 30

32 CONCLUSION AND QUESTIONS 31

33 Contact Information Jennifer Aubel Aronson LLC Phone: (301) Barbara Connell Aronson LLC Phone: (240)

The Ten Commandments of GSA Schedule Compliance

The Ten Commandments of GSA Schedule Compliance Breakout Session #: B05 Jennifer Aubel Aronson LLC Date: Monday, July 25 Time: 2:30pm 3:45pm About Aronson LLC Aronson LLC provides a comprehensive platform