By Julia Coon,
The General Services Administration (GSA) started the mass modification roll-out of the Commercial Supplier Agreement (CSA) final rule into all Federal Supply Schedules this week. Mass modification roll-out for Order-Level Materials (OLMs) eligible Schedules will begin following acceptance of the CSA mass modification.
Following is a summary of the steps for accepting these mass modifications. Please note that this will be a multi-step process for the OLM authorized Schedules and the CSA mass modification must be accepted before the OLM mass modification will be issued.
All Schedule contractors must accept the mass modification adding GSAR clause 5552.212-4 Contract Terms and Conditions Commercial Items (JAN 2017)(DEVIATION – FEB 2018)(ALTERNATE I – JAN 2017)(DEVIATION – FEB 2007) incorporating the CSA rule into the contract. This mass modification will also include updated Service Contract Labor Standards (SCLS) Wage Determinations for all solicitations.
Following acceptance of the CSA mass modification, another mass modification will be issued to contractors with the seven OLM authorized Schedules currently identified as 03FAC, 56, IT70, 71, 84, PSS, and 738X. Please note that GSA may authorize additional Schedules in the future. If you wish to participate, Schedule contractors must accept the mass modification that automatically adds the OLM Special Item Number (SIN) and GSAR clause 552.538-82 Special Ordering Procedures for the Acquisition of Order-Level Materials to the existing contract.
Once the mass modification has been accepted, the new OLM SIN will populate across the GSA eTools including GSA eLibrary. Contractors can then start to propose OLMs in response to customer requirements.
What are the CSA and OLM Rules?
The CSA final rule defines unenforceable obligations and clauses in addition to outlining the order of precedence Contracting Officers and industry must follow. The intent of the rule is to streamline CSA negotiations.
The OLM final rule provides Contracting Officers the authority to acquire OLMs when placing task or delivery orders against a Federal Supply Schedule (FSS) or FSS Blanket Purchase Agreement (BPA). OLMs are supplies and/or services acquired in direct support of an individual task or delivery order placed against an FSS Schedule or BPA when the supplies and/or services are not known at the time of Schedule or BPA award.
Your GSA Schedule contract administrator should be on the lookout for the email from GSA with the PIN number to accept the mass modification. After the CSA mass modification is accepted, be on the lookout for the next PIN number to accept the OLM mass modification.
About the Author:
Julia Coon is GSA and VA Contract Consultant at Centre Law & Consulting. Julia works with the GSA/VA team in preparing new schedule proposals and post-award contract administration. She has experience in producing schedule renewal packages, various modification packages, small business subcontracting plans, and updates to GSA pricelists.