GSA Schedules - News, Updates and Compliance

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2 GSA Schedules - News, Updates and Compliance Breakout Session #: F17 Maureen Jamieson, Centre Law & Consulting LLC Date: Tuesday, July 26 Time: 4:00pm 5:15pm

3 FASt Lane Initiative (Pilot Program for IT 70 only) FASt Lane: 45 days for new offers and less than 48 hours for modifications. Must provide answers to CO s inquiries within 48 hours. Once your offer is submitted, immediately contact the FASt Lane team at FAStLane@gsa.gov. 2

4 IT Health SIN SIN Description Includes a wide range of Health IT services to include connected health, electronic health records, health information exchanges, health analytics, personal health information management, innovative Health IT solutions, health informatics, emerging Health IT research, and other Health IT services. 3

5 IT Health SIN The General Services Administration s Federal Acquisition Service (FAS) and the Defense Health Agency (DHA) entered into a strategic seven-year partnership representing an estimated $5.4 billion in spend for critical Health IT services and solutions. 4

6 IT Health SIN Review Contract Modification and New Offer Instruction Package. Address a new technical factor Relevant Health IT Project Experience. May use commercial or government experience as a prime or subcontractor. Need 3 completed or ongoing projects related to Health SIN experience. 5

7 IT 70 Startup Springboard Allows innovative IT companies with fewer than two years of experience to: Use the professional experience of their executives and key personnel as a substitute for having two years of corporate experience; Use the project experience of key personnel as a substitute for having relevant corporate past performance; and Provide financial documentation that demonstrates the company's financial responsibility in lieu of submitting two years of financial statements. 6

8 Contract Continuity Initiative Many contractors under the FSS programs are approaching the end of their 20-year contract period. GSA s solution for this situation is to allow for the award of overlapping or continuous contracts. These are in essence duplicate FSS contracts for the same items. A contractor can now submit an offer for a new contract for the same schedule at any time under its existing FSS contract. 7

9 Contract Continuity Initiative If the contract has one or more active BPAs or orders under its existing contract, it is eligible for the award of a new contract that is allowed to overlap and run alongside the existing one. Holding continuous contracts enables the FSS contractor to complete work under BPAs and orders awarded via the existing contract, while utilizing the new contract for new business opportunities. 8

10 Successful Contractor Offer Process Offers can be submitted per the streamlined approach provided the contractor meets ALL of the following criteria: Must have an existing FSS contract under the same schedule and submit a new offer for the same SINs. Sales under the existing contract have averaged a minimum of $25,000 per year for the previous five years of reported sales. Demonstrated pattern of satisfactory past performance under the existing contract. 9

11 Formatted Product Tool The Formatted Product Tool (FPT) is a systems upgrade that will be activated within the existing eoffer and emod platforms and NOT a separate application. GSA plans to implement the FPT across the Multiple Award Schedules (MAS) program beginning with select pilot Schedules in late July Participation is optional if you are on one of the pilot schedules. 1 0

12 Transactional Data Reporting (TDR) June 23, GSA amends the General Services Administration Acquisition Regulation (GSAR) to include clauses that require vendors to report transactional data from orders placed against certain Federal Supply Schedule (FSS) contracts, Governmentwide Acquisition Contracts (GWACs), and Governmentwide IDIQ contracts. Transactional data refers to the information generated when the Government purchases goods or services from a vendor. It includes specific details such as descriptions, part numbers, quantities, and prices paid for the items purchased 11

13 TDR The TDR clause is being implemented under the GSA Schedules program on a pilot basis. TDR implementation for several Schedules and Special Item Numbers (SINs) will begin in August 2016 and extend through Q1 FY2017. Currently, GSA plans for a 3-year pilot affecting specific SINS at which point the pilot will be reassessed. The new TDR requirements will be mandatory only for new Schedule contracts awarded after the Schedule becomes subject to the pilot and at the time to extend the term of the Schedule contract. 1 2

14 TDR Vendors holding existing contracts under pilot Schedules will be encouraged to accept the new clause via a bilateral contract modification. Once accepted, vendors will not need to comply with the Commercial Sales Practices (CSP) and Price Reductions Clause (PRC). Contractors in the pilot program will have ninety (90) days to accept the Mass Mod incorporating TDR. TDR data is reported monthly, and there is a 30- day window to report after the end of the month. 1 3

15 Compliance Contractor Assessments (formerly CAVs) Trade Agreement Act (TAA) Price Reductions Clause 1 4

16 Contractor Assessments CAVs now called Assessments Virtual assessments are becoming more frequent Annual visits for Contractors with sales over $150K End of Term Assessment prior to option renewal exercise Increased scrutiny on resumes and IFF detailed analysis No more Report cards; assessments will be provided to Contractor at the end of the Assessment 1 5

17 Trade Agreements Act The Trade Agreements Act (TAA) prohibits the U.S. Government from buying products and services from non TAA-eligible countries such as China or India. TAA is applicable to all federal supply schedules. 1 6

18 TAA Due Diligence What is the country of origin for the product? How do I know this and do my records substantiate this information? How current is the information? Who do I contact when I am not sure? 1 7

19 TAA Compliance Internal policies Training and Awareness Track and Automate Communicate with your vendors Make mandatory disclosures regarding selling non-compliant TAA products Revise and update your policies and internal checks 1 8

20 The Price Reductions Clause The importance of understanding the Price Reductions Clause (PRC) 1 9

21 The Basis of Award (BOA) What is the BOA? Understanding and establishing the BOA Negotiating your BOA Your goal 2 0

22 Commercial Sales Practices (CSP) What information is required for submissions? Questions to answer Effective Disclosures Deviations, Concessions, and Discounts 2 1

23 Final Proposal Revision (FPR) Why is the FPR important? What should be included in your FPR? 2 2

24 Contact Information Maureen Jamieson Centre Law & Consulting LLC 23