GSA will visit you to make sure you're tracking your GSA sales properly. GSA's auditors will also pay close attention to whether you have offered better pricing to the "basis of award group" defined under your GSA Schedule contract. If your company offered better pricing to your basis of award group customers and didn't notify your contracting officer, you may be subject to a fine. Furthermore, your company will be forced to lower your GSA Schedule prices to those offered to your basis of award customers.

The GSA Vendor Support Center provides a wealth of information on the "Contractor Assistant Visit." Such audits are also called "Administrative Compliance Visits."

CAV FREQUENTLY ASKED QUESTIONS (ACCORDING TO GSA WEBSITE)

1. WHAT IS THE PURPOSE OF THIS VISIT?

This is a Multiple Award Schedule System Review. This review is being conducted to ensure that an adequate sales tracking system is in place. The system should include supporting documentation to substantiate the sales data submitted. The tracking system will be evaluated to ensure that the process can accurately report all 72A Sales Data and submission of the Industrial Funding Fee (IFF) check to GSA.

Fedmarket comment:

The Industrial Operations Analyst (the "IOA"), or the person who performs this review, is known to call a day or two before the visit. As a result, you will have to scramble to pull together the information. It is critical that your business has a system in place to track all GSA sales, report them to GSA and then send in the 0.75% Industrial Funding Fee. If you get your systems in place and get last-minute notice of a visit, you'll be ready. Have a second individual at your company educated on the processes as well.

You will need to show all invoices of items sold to the government and the IOA will review them very carefully to make sure every item is on the GSA Schedule.

2. HOW LONG WILL THE REVIEW TAKE?

A typical review will take approximately 2 - 5 hours based on the complexity of the tracking system. Follow-up visits may be necessary if inconsistencies are found.

Fedmarket comment:

The stated time-frame is accurate.

3. WHAT RECORDS WILL I NEED TO HAVE AVAILABLE?

GSA will need access to all records pertaining to sales. Records that should be made available include, but are not limited to, sales journals, purchase orders, invoices, approved GSA prices/lists, Requests for Quotations (RFQ's), open market government order records, any authorized dealer sales records,teaming arrangements, etc.

Fedmarket comment:

GSA likes to see that that your business has a system in place which tracks all of your GSA sales and separates them out in some way. The IOA will ask you to generate a report that shows what you are selling and quoting to the government.

4. WHAT KINDS OF QUESTIONS WILL THE GSA INDUSTRIAL OPERATIONS ANALYST BE ASKING?

The questions will be geared toward evaluating the reliability of your tracking system. As the 72A Representative, it is important that you be able to communicate your method of tracking 72A sales data and your company's records maintenance system to substantiate the reported data.

Fedmarket comment:

The auditors might watch you enter an order into your system or ask to observe how an order is taken to see how the steps are implemented on the front lines.

5. WHAT HAPPENS IF YOU FIND PROBLEMS WITH MY SYSTEM?

If problems exist, we will lend our expertise and work with you to develop an acceptable system. We will also allow you reasonable time in which to make corrections.

Fedmarket comment:

If you have an internal computer quotation and invoicing system and your sales people are located in different offices throughout the country, consider having an internal warning system built into your quoting system. Your established system should prevent your sales staff from offering pricing lower than your approved GSA pricing. The IOA will be impressed by the internal procedures you have put in place. Here is an example of wording you can build into your system:

WARNING: You are not authorized to offer a discount equal to or greater than our organization's federally-approved pricing. For further questions, contact your manager.

6. HOW FREQUENTLY WILL YOU VISIT?

If your system is determined to be acceptable, you will not be visited again for at least one year. If your system has problems, we will conduct appropriate follow-up visits to verify that you have made corrections.

Fedmarket comment:

This is not guaranteed but the IOA will most likely take notes of their visit with you. If they give an issue a "pass" this year, you must have the issue fixed by the next visit.

7. WHO SHOULD I HAVE PRESENT DURING THIS VISIT?

Only the designated 72A Contact need be present during the visit. Additional personnel should be present if deemed necessary to demonstrate the sales tracking system adequacy.

Fedmarket comment:

Do not have more than two people from your company meet with the IOA. By doing so, you will have kept the situation from becoming too confusing and emotional. The designated 72A person at your company should know all of the ins and outs of your contract, how sales are entered into your system and how your company is tracking GSA sales and sending in the IFF checks. Should the IOA discover problems, ask for forgiveness and a second chance. They will be more helpful and an advocate on your behalf if you ask them to "teach me how to make this system better, since you see systems like mine every day."

8. WILL I BE EVALUATED ON MY PERFORMANCE IN SUBMITTING THE 72A REPORTS AND IFF CHECK (S)?

Yes. The Procuring Contracting Officer (PCO) will be advised of contractors who submit their 72A Cards and IFF Checks accurately and on time. The PCO will also be advised of those contractors whose reports and checks are late and contain errors. Contractors who do not perform in accordance with the provisions of the clauses run the risk of not being recommended for future awards or cancellation of their current contract.

Fedmarket comment:

It is essential that you have proof that you've sent in your reports and paid your IFF on time.

FURTHER NOTES:

The IOA will compare your Schedule contract invoices with those from your named "Most Favored Customer" group or "Basis of Award" customer group. They need to ensure you have not offered such customers lower prices than those offered to GSA. Note that the IOA is permitted to look at any invoice from your basis of award group but not invoices from customers that are outside that group.

If your sales are unimpressive or less than $25,000, you may receive a warning from the IOA. In fact, GSA has the right to drop you as a contractor if you are not meeting the contract minimum of $25,000 in annual sales. The IOA may ask to review your marketing plan to the government. You will need to put together a one-page document on what you are doing to uncover business with the federal government. This could include providing a list of trade shows you have attended, copies of your mailing lists, copies of RFP's and RFQ's you've completed, a list of the classes you've attended, the lists you've purchased, etc. If you have a sales manager responsible for selling to the government or a web site with GSA information, provide your web site address and the name of the government sales manager to the IOA. And, finally, GSA will check to see if your prices are posted at GSAAdvantage!, the GSA Schedule contractor web site.