Apr 19, 2018

By Maureen Jamieson, Executive Director of Consulting

Hopefully, you have been following the breaking news regarding the final rule on Order-Level Materials (OLMs). After many years of discussion on this subject, the General Services Administration (GSA) is amending the General Services Administration Acquisition Regulation (GSAR) providing the authority to acquire OLMs when placing task or delivery orders against a Federal Supply Schedule (FSS) or FSS Blanket Purchase Agreement (BPA).

And exactly what is the definition of OLMs?  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. Please note that Other Direct Costs, which are known at the time of schedule award, will remain as an option. Examples of these types of Other Direct Costs can be found on the Professional Services Schedule (PSS) under the Ancillary and Other Direct Cost SIN descriptions.

Key points of the OLM final rule:

  • The total value of all OLMs cannot be greater than one-third the volume of the total order. (Note that travel is excluded from this calculation).
  • Fair and reasonable pricing, defined as a minimum of three (3) quotes for each OLM exceeding the Simplified Acquisition Threshold, will be required. However, contractors with approved purchasing systems are exempt.
  • Indirect Costs on OLMs are allowed. GSA training is being updated to address indirect cost application.
  • Industrial Funding Fee (IFF) will be incorporated into pricing at the Task Order level.

What are the next steps?

  • Advanced notice of the OLM final rule will be provided this month on interact.gsa.gov. Be sure to review and provide comments back to GSA.
  • Next month, look for OLM webinars hosted by GSA. The month of May will also kick off GSA wide internal training including training for Industrial Operations Analysts.
  • GSA expects to issue Mass Modifications for the addition of OLMs by June or July 2018. You will have ninety (90) days to accept or decline this OLM mod. When and if you accept the forthcoming OLM Mass Modification, a new OLM SIN will be created.  This new SIN will automatically be uploaded into e-library on GSA Advantage.
  • Centre Law & Consulting will keep you updated on OLM developments via our LinkedIn group GSA Schedule News, Updates, & Discussions.

We hope to see you at Boot Camp for GSA Schedules on May 8-9. You can bring your colleague for free*! You’ll gain the necessary skills to understand and negotiate your own GSA Schedule and/or make modifications to an existing schedule, as well as keep up with the changes that affect your contract administration and compliance efforts.

*Promotion expires May 1.

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