GSA New Consolidation Phase
by Kennedy O'Shea
GSA, GSA Alerts, GSA Schedules
GSA recently implemented a new MAS Consolidation Phase, Phase 3. Per this new guidance, a consolidation is required for any company which manages two or more MAS contracts which have the same Unique Entity Identifier (UEI), which for many companies will be a Data Universal Numbering System (DUNS) number. These contracts will be consolidated into a single surviving contract for the company which is tied to that Unique Entity Identifier. If your company fits into one of the following scenarios, Phase 3 does not apply to you:
- You have two contracts and one of them has a small business set-aside (SBSA) Special Item Number (SIN). Please note that if you have more than two non-SBSA contracts, then these must be consolidated.
- One contract is a follow-on contract with the same SIN(s)
- One contract already has the same SIN(s) and products/services which are already awarded on another contract.
In order to begin your Phase 3 consolidation, you will need to fill out a contractor checklist and plan. This plan will document how and when they will consolidate their multiple contracts into one. This consolidation checklist and plan must be submitted and approved by the contractor’s PCO prior to submitting any streamlined “add SIN” modifications. These checklists and plans were due to contracting officers no later than 12/31/2021, so if you have not yet submitted your plan this will need to be done as soon as possible, and no later than 04/30/2022.
For contractors who have three or more contracts tied to a single UEI, they are not required to consolidate all of the individual MAS contracts at the same time and may do so in multiple phases. This could take the form of a single contract modification request or the submission of an entirely new offer which incorporates the components of each prior contract.
If you need help beginning this process or have questions, including questions regarding whether your company needs to consolidate at this time, feel free to contact the GSA Team at Centre Law and Consulting. Our consultants can help your company fill out this checklist, answer questions about the steps that need to be taken once it has been filled out, and assist with the uploading of modifications which may be required along the way as you go through the process of consolidating.