Eliminate GSA Schedule Audit Risk with a Compliance Program

Many contractors get an award of a GSA Schedule contract and think that their work is complete. The reality is that the tough work has really only begun. Compliance issues are of critical importance and are often overlooked or even ignored. Smart companies implement a GSA Schedule compliance program and oversee that program with great care.

The painful truth is that some companies do not really want to comply with the Schedule contract's provisions and restrictions because of the lost flexibility in discounting to non-GSA customers. The economic and legal realities are that your company cannot afford not to comply with the terms and provisions of your GSA contract. Contrary to common belief, discounting discipline can be a good thing (e.g., your sales may decrease slightly but your profits may have increased).

GSA Compliance Officer

A single person, preferably a member of your accounting or financial staff, should be designated as the GSA Compliance Officer. The designated person must have the authority to ensure GSA contract compliance and be held accountable for keeping the company in compliance.

Implement systems and procedures to support your GSA Compliance Officer. The focus of the required systems and procedures should be (1) GSA order segregation in your accounting system and (2) effective discounting policies and procure to keep your sales staff from violating the price reduction clause.

In summary, the three C's of effective GSA contract management and administration are compliance, communication, and common sense. GSA contract administration is not complex. Know what the contract says and pay particular attention to the clauses that have financial ramifications. Follow the letter of the contract and don't play discounting games. Make accurate discounting disclosures, monitor price reductions to your basis of award group, and pay the IFF on time. Don'' cut corners. If you discover problems, correct them immediately and communicate the problem and the corrective action taken to your GSA contracting officer.



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