By Julia Coon,
Clause 552.238-74 Industrial Funding Fee and Sales Reporting requires all General Services Administration (GSA) Schedule contractors to report sales within 30 calendar days following the completion of the reporting period and remit the Industrial Funding Fee (IFF) within 30 calendar days following the end of each reporting quarter.
Over the next twelve months, GSA will be transitioning all GSA Schedule contracts from the legacy 72A Reporting System to the new Federal Acquisition Service (FAS) Sales Reporting Portal (SRP). The process will take place in three phases:
Phase One: Notification
Contractors will receive an email from GSA stating the date to begin reporting sales and submitting IFF in the FAS SRP. The date provided will be the first day of a reporting quarter, and no action is required until the end of the reporting period when it is time to report sales and submit the IFF.
Example: The contract is assigned a 1/1/2019 transition date, but no action is necessary until the January – March 2019 sales are required to be reported by April 30, 2019.
Phase Two: Final Reporting in the 72A Reporting System
Contractors will complete the final sales report and IFF remittance in the legacy 72A Reporting System.
Example: If the contract is assigned a 1/1/2019 transition date, the October 2018 – December 2018 sales and IFF will be the final report in the 72A System.
Phase Three: Transfer History from Legacy 72A Reporting System to the new FAS SRP
GSA will migrate the contract sales history to the FAS SRP. This will not occur until contractors have completed the last sales report in the 72A System. If there is a discrepancy between the IFF owed versus the IFF paid, contractors will be notified via email before the migration.
Where do you stand?
Contractors who are not participating in the Transactional Data Reporting (TDR) pilot will continue to report quarterly sales by Special Item Number (SIN) and remit IFF in the new system within 30 days following completion of the reporting quarter. Contractors who are participating in the TDR pilot should already be completing reporting requirements in the FAS SRP.
Currently digital certificates are required to access the FAS SRP; however, the MAS Program Management Office confirmed that GSA will be moving to a multi-factor authentication process in the coming months. All users will be required to register in the new system even if you are currently using a digital certificate to access the system. At the time of registration, you will have the option to select receiving the security code via phone or email. Contractors using a generic email address should choose to receive the security code via email at the time of registration.
Once registered in the FAS SRP, users will be able to access any GSA Schedule contract where their email address appears on the contract. To prepare for this transition, it is essential to review all authorized negotiators and points of contact currently listed on the contract to ensure anyone reporting sales and remitting the IFF is included. If updates are needed, you will need to submit a modification in the eMod system for your Contracting Officer’s approval.
If you are unsure which reporting system to use during the transition, you can look up your contract using the VSC Sales Reporting Lookup Tool. If you have any questions regarding the change or using the new FAS SRP, you can reach out to our GSA consulting team.
Want to learn more? Attend our Boot Camp for GSA Schedules training course.
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 price lists.