There are a lot of things going on at GSA right now, and this blog post will summarize some of them.
First, GSA is making a lot of technical changes. The FAS Catalog Program (FCP) is replacing the legacy SIP, providing much easier catalog updates to Schedule holders. GSA is also moving all schedules to Transactional Data Reporting (TDR), which requires more reporting from Schedule holders, but eliminates the Price Reduction Clause from contracts. This should make compliance much easier. Not all GSA Contracting Officers are fully onboard with some of the transitions; some are using their discretion to require documentation phased out by the move to TDR.
Second, the DOD is pressuring resellers on the GSA Schedule to reduce their margins on resold goods. This will likely include a cap on profits and an independent price evaluation. At first, this will be focused on IT products under SIN 33411. We expect it to expand to other SINs, such as software. These extra requirements imposed by DOD on top of the existing GSA Schedule requirements will make it more difficult for resellers to successfully perform on the GSA Schedule. It will also make procurement more difficult on DOD.
Third, consolidation is ongoing. More purchasing across the government will occur out of GSA. Some of this purchasing will be through the GSA Schedule, while some will be through other GSA contracting vehicles, like OASIS. It is critical that all GSA Schedule holders ensure they are compliant and in position to compete for opportunities issued under the GSA Schedule.
These changes will fundamentally change how government contractors use and manage their GSA Schedules. If you need help in modifying your GSA Schedule, getting a GSA Schedule, developing your strategy, creating a compliance program, or getting into compliance, reach out at bgraves@centrelawgroup.com.
