Government Contracting - FAR Supplements - GSA - General Services Administration

FAR SUPPLEMENTS
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2022

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WEBINAR WEDNESDAY - Schedule At A Glance
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1/12/22 – FAR
1/19/22 – FAR CAS
1/26/22 – DOD
2/2/22 – DPGI
2/9/22 – ARMY
2/16/22 – AIR FORCE
2/23/22 – DISA
3/2/22 – DLA
3/9/22 – USMC
3/16/22 - SPECIAL OPS
3/23/22 -TRANS COMMAND
3/30/22 – AGRICULTURE
4/6/22 – AIDAR
4/13/22 – DOC
4/20/22 – DOE
4/27/22 – DOI
5/4/22 – DOL
5/11/22 – DOS
5/18/22 – DOT (Treasury)
5/25/22 – DOEd
6/1/22 – EPA
6/8/22 – FEHB
6/15/22 – GSA
6/22/22 – HHS
6/29/22 – DHS
7/6/22 – HUD
7/13/22 – BBG
7/20/22 – DOJ
7/27/22 – OPM
8/3/22 – NASA
8/10/22 – NRC
8/17/22 – DOT (Transportation)
8/24/22 – VA

FRIDAY PLAYBOOKS - Schedule At A Glance
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1/12/22 – N/A
1/19/22 – N/A
1/28/22 – DOD
2/2/22 – N/A
2/11/22 – ARMY
2/18/22 – AIR FORCE
2/25/22 – DISA
3/4/22 – DLA
3/11/22 – USMC-NAVY
3/18/22 - SPECIAL OPS
3/25/22 -TRANS COMMAND
4/1/22 – AGRICULTURE
4/8/22 – AIDAR
4/15/22 – DOC
4/22/22 – DOE
4/29/22 – DOI
5/6/22 – DOL
5/13/22 – DOS
5/20/22 – DOT (Treasury)
5/27/22 – DOEd
6/3/22 – EPA
6/10/22 – FEHB
6/17/22 – GSA
6/24/22 – HHS
7/1/22 – DHS
7/8/22 – HUD
7/15/22 – BBG
7/22/22 – DOJ
7/29/22 – OPM
8/5/22 – NASA
8/12/22 – NRC
8/19/22 – DOT (Transportation)
8/26/22 – VA

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2022 – FAR SUPPLEMENT – GSAM/R – General Services
Date: Wednesday, June 15, 2022
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GENERAL SERVICES ADMINISTRATION
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SPEAKER
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LOGO HERE
2022 – FAR SUPPLEMENT – GSAM/R – GENERAL SERVICES
202-365-0598
SPEAKER
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MEET OUR SPEAKER
Daniel H. Ramish
Smith Patcher McWhorter PLC
dramish@smithpachter.com
(703) 847-6300
Disclaimer: The content of this presentation is not intended to serve as legal advice related
to any individual situation. This material is made available for information purposes only.

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• Introduction to GSA and the GSAR/GSAM
• Part 538—Federal Supply Schedule Contracting
• Commercial Sales Practices Format
• Price Reductions and Economic Price Adjustments
• Transactional Data Reporting
• Industrial Funding Fee and Sales Reporting
• Order-Level Materials
• Schedule Modifications and Audits
• Other Items of Interest
• Unenforceable Terms
• Interagency Acquisitions
• Leases
Agenda

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• Federal Supply Schedules Program
• 11M+ commercial supplies and services offered, $30B+ per year spent
• 3,000+ contractors “on Schedule”
• Major IT acquisition vehicle (formerly Schedule 70)
• Other Inter-Agency Agreements
• Governmentwide Acquisition Contracts (GWACs)
• Multi-Agency Contracts (MACs)
• Real Property Role
• GSA manages more than 370 million square feet of owned and leased space
for Federal agency tenants
Introduction to the General Services Administration (GSA)

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• General Services Administration Acquisition Regulation (GSAR)
(48 C.F.R. Ch. 5)
• GSA’s supplemental procurement regulations
• Parts 501-553 of the GSAR correspond to FAR Parts 1-53
• Part 552 includes the Solicitation Provisions and Contract Clauses
• 552.238-70 through -116 = Federal Supply Schedule Contract Clauses
• Parts of Special Note:
• Part 538 Federal Supply Schedule Contracting
• Part 570 Acquiring Leasehold Interests in Real Property
• GSA Acquisition Manual (GSAM)
• Internal agency acquisition policy
• Not regulatory and applies only internally to GSA
Introduction to the GSAR and GSAM

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• FSS/MAS Contracting Program Overview
• Commercial products and services contracting vehicle with standing solicitation
• Long-term contracts (20 years: 5-year base period and three 5-year options)
• Blanket purchase agreements (BPAs) can be issued under schedule contracts
• Schedule consolidation now combining 24 legacy Schedules into single Schedule
• Exempt from Small Business “Rule of Two” (see FAR 8.404(a))
• Regulations
• GSAR Part 538 Federal Supply Schedule Contracting
• FAR Subpart 8.4 Federal Supply Schedules
• FAR Part 38 Federal Supply Schedule Contracting
• Some important Schedule concepts not addressed in regulations or even manuals,
e.g., Contractor Teaming Arrangements (CTAs)
Federal Supply Schedule (FSS), aka Multiple Award Schedule (MAS)

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• 538.270–1 Evaluation of offers without access to transactional data.
• Government policy is to “negotiate concessions from established [commercial]
catalogs, including price and non-price terms and conditions”
• Government’s objective is to seek offeror’s best (most-favored customer) price.
• Contracting Officer compares MAS and commercial terms considering:
(1) aggregate volume of anticipated purchases; (2) minimum quantity purchases and
historic purchasing patterns; (3) prices taking into account discounts/concessions
offered to commercial customers, (4) length of contract period; (5) warranties,
training, and maintenance, and whether priced separately or included; (6) ordering
and delivery practices; (7) other information warranting a lower discount for the
Government
Solicitation, Evaluation and Award of Schedule Contracts

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• 538.270–1 Evaluation of offers without access to transactional data.
• Contracting Officer is instructed: “If the best price is not offered to the Government,
you should ask the offeror to identify and explain the reason for any differences. Do
not require offerors to provide detailed cost breakdowns.”
• Contracting Officer may award contract with other than best price if:
(1) prices are fair and reasonable (even though comparable discounts were
not negotiated); and
(2) award is otherwise is the Government’s best interest
• Contracting Officer is instructed to: “state clearly in the award document the
price/discount relationship between the Government and the identified
commercial customer (or category of customers) upon which the award is
based” – referred to as “basis of award” (“BOA”) customer
Solicitation, Evaluation and Award of Schedule Contracts

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• CSP Format is the centerpiece of a GSA Schedule offer, disclosing commercial sales
information for the goods and services the contractor intends to offer on Schedule
• CSP informs the GSA CO whether the prices offered the USG are equal to or better
than Most Favored Customer (MFC) prices. If not, the CO will seek to negotiate
better terms and/or require documentation justifying less favorable prices/discounts.
• 515.408(b) Commercial Sales Practices Format
(1) Dollar value of sales to the general public at or based on an established catalog or
market price during the previous 12–month period or offerors last fiscal year
(2) Projected annual sales to the Government under this contract for the contract
term, excluding options, for each SIN offered (based on most recent 12 months of
sales if you already hold a Schedule contract for the same SIN)
Commercial Sales Practices (CSP)

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• 515.408(b) Commercial Sales Practices Format
(3) Based on your written discounting policies (standard commercial sales practices if no
written policies), are the discounts and any concessions which you offer the Government
equal to or better than your best price (discount and concessions in any combination)
offered to any customer acquiring the same items regardless of quantity or terms and
conditions? YES__ NO__
(4)(a) CSP Matrix:
(4)(b) Do any deviations from your written policies or standard commercial sales practices
disclosed in the above chart ever result in better discounts (lower prices) or concessions
than indicated? YES _ NO _. If YES, explain deviations per Figure 515.4.
Column 1
Customer
Column 2
Discount
Column 3
Quantity/Volume
Column 4
FOB Term
Column 5
Concessions

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• Information in CSP must be current, accurate, and complete
• Offerors must disclose changes to commercial pricelists, discounts, or discounting
policies that occur between offer submission and completion of negotiations
• 552.215-72 Price Adjustment—Failure To Provide Accurate Information.
• Government can reduce prices if it finds the contractor:
• Failed to provide all required information
• Submitted outdated, inaccurate, or complete information
• Changed pricing/discounts between submission and completion of negotiations
• Information must be current, accurate and complete within 14 calendar days of the
date it is submitted

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• Most-Favored Customer (“MFC”) Prices and Discounts
• Contractors are not required by law or regulation to offer the Government MFC prices.
Most companies do not offer their best price in their Schedule proposals. GSA Schedule
guidance for agencies suggests requesting additional discounts on orders.
• If you do not offer MFC prices, factors at 538.270–1(e) can provide support.
• Basis of Award (”BOA”) Customer
• Customer or category of customer that will serve as baseline for price reductions
• Offeror is not required to propose that USG receive the same prices/discounts as BOA
customer; just required to maintain the price/discount relationship (i.e., ratio)
• Government tries to define BOA broadly to include, e.g., all sales or all commercial sales
• Contractor will want to define narrowly, to ensure PRC compliance is manageable
• Must clearly show relationship between proposed price, BOA, and commercial price list
Take-Aways for Schedule Offerors

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• 552.238–81 Price Reductions
• Before award, Contracting Officer and Offeror will agree on: (1) basis of award
customer (BOA) (or category of customers), and (2) price or discount relationship.
• Relationship must be maintained throughout the contract period, and any change to
Contractor’s commercial pricing or discount arrangement to BOA customer that
disturbs the price/discount relationship constitutes a price reduction
• Contractor is required to report the Contracting Officer price reductions to BOA
customer, including explanation of conditions under which the reductions were made
• Notice of price reductions required “as soon as possible, but not later than 15
calendar days after its effective date”
Price Reductions Clause (PRC)

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• Price reduction is triggered if, after the date negotiations conclude, the Contractor—
(i) Revises the commercial catalog, pricelist, schedule or other document upon which
contract award was predicated to reduce prices;
(ii) Grants more favorable discounts or terms and conditions than those contained in the
commercial catalog, pricelist, schedule or other documents upon which contract award
was predicated; or
(iii) Grants special discounts to the customer (or category of customers) that formed the
basis of award, and the change disturbs the price/discount relationship of the Government
to the customer (or category of customers) that was the basis of award.

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• Events that do not trigger the price reductions clause:
• Discounts to commercial customers under firm, fixed-price definite quantity
contracts in excess of the specified maximum order threshold in the Schedule;
• Discounts to Federal agencies, or to state and local government on Schedule orders;
• Errors in quotation or billing (provided they are adequately documented).
See also 538.272 FSS price reductions
Contractor PRC Compliance Note:
• Must maintain relationship between: GSA price, BOA price, and commercial list price.
• Requires a compliance program ensuring ongoing communication between contracts
and sales folks or others who decide sales/discounting practices.

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• Transactional Data Reporting (TDR) is an alternative to the CSP/PRC approach. TDR requires
contractors report transactional data to GSA each month for a “prices paid” database.
• 552.216–75 Transactional Data Reporting
• Transactional data elements required to be reported, within 30 calendar days:
Transactional Data Reporting (TDR) Pilot Program
(i) Contract or Blanket Purchase Agreement (BPA)
Number.
(vii) Unit Measure (each, hour, case, lot).
(ii) Delivery/Task Order Number/Procurement Instrument
Identifier (PIID).
(viii) Quantity of Item Sold.
(iii) Non Federal Entity. (ix) Universal Product Code.
(iv) Description of Deliverable. (x) Price Paid per Unit.
(v) Manufacturer Name. (xi) Total Price.
(vi) Manufacturer Part Number.

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• 552.216–75 Transactional Data Reporting
• Reporting is accomplished through “automated reporting system at an Internet
Web site designated by the General Services Administration (GSA) or by uploading
the data according to GSA instructions,” per details in the contract.
• GSAM 538.270-2 Evaluation of offers with access to transactional data
• In negotiating Schedule contracts with TDR, COs are instructed to use: (i) Prices
paid information on contracts for the same or similar items, (ii) Contract-level
prices on other MAS contracts or other government-wide contracts for the same
or similar items, and (iii) Commercial data sources that consolidate and normalize
prices offered by commercial vendors to the general public to compare prices for
the same or similar items. Next, CO is supposed to perform market research.
• However, COs can (and often do) require “other than certified cost or pricing
data”
Transactional Data Reporting (TDR) Pilot Program

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• GSA announced last year that the TDR program would be continued and expanded.
• GSA’s Office of Inspector General (“OIG”) issued an audit report for the TDR program, which
concluded TDR data is inaccurate and unreliable and that COs are not using it, and
recommended the program be discontinued. GSA agreed corrective action was needed but
disagreed with the recommendation. GSA OIG, GSA's Transactional Data Reporting Pilot Is
Not Used To Affect Pricing Decisions, Report No. A140143/Q/6/P21002 (June 24, 2021).
• Industry groups have supported the expansion of the TDR program. See, e.g., GSA’s
Transactional Data Reporting pilot: A thoughtful way forward, Roger Waldron, CGP, Federal
News Network (Sept. 17, 2021) (“TDR recognizes that pricing and best value are driven by
competition at the order level for agency-specific requirements” and “reduces administrative
burdens and risk on MAS contractors as compared to the outdated, anti-competitive legacy
MAS pricing policies, especially the Price Reduction Clause (PRC)”).
The Future of the TDR Program

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• The GSA Schedules program is “self-funded” via the industrial funding fee (IFF), a fee used
to cover GSA’s cost of administering Schedule contracts (and then some)
• Schedule prices are required to be inclusive of IFF (built in, not as a separate line item)
• 552.238–80 Industrial Funding Fee and Sales Reporting
• Contractors are required to report Schedule sales and pay the IFF on a quarterly
basis for traditional CSP and monthly for TDR (Alt. 1 Version of the clause), in
either case within 30 days of the end of a reporting period
• Reported sales must include amount of IFF, and “zero” sales must also be reported
• IFF is due within 30 days of the end of the reporting period, calculated as a
percentage of sales for the period, currently 0.75%
Contract will include directions on payment of IFF. Mechanics are similar to sales tax.
Industrial Funding Fee (IFF) and Sales Reporting

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• 552.216–70 Economic Price Adjustment—FSS Multiple Award Schedule
• Contractors may request price increases under the following conditions:
(1) Increases from changes to Contractor's commercial catalog/pricelist used as basis for award.
(2) Only three increases will be considered during the contract period.
(3) Increases are requested after the first 30 days of the contract period and prior to the last
60 days of the contract period.
(4) At least 30 days elapse between requested increases.
• EPA clause includes a maximum aggregate unit price increase percentage, which is
“normally be 10%” unless the contracting director approves a different rate
• On multi-year contracts an increase is not available in the first year, and the aggregate
maximum percentage caps and max of 3 increases apply for each contract year
See also 552.216–71 Economic Price Adjustment—Special Order Program Contracts, based on PPI
Economic Price Adjustments

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• In March 2022, GSA’s Senior Procurement Executive issued a letter granting flexibility for
economic price adjustments on Schedule contracts under 552.216-70. Temporary
Moratorium on Enforcement of Certain Limitations Contained in Certain GSA Economic
Price Adjustment (EPA) Contract Clauses, Letter MV-22-02 (Mar. 17, 2022).
• Effective until September 30, 2022, the Letter:
1. Lowers the approval for price increases above the EPA clause ceiling in 552.216-70, from
the contracting director to one level above the contracting officer;
2. Relaxes time limitations on EPA increases;
3. Relaxes limitations on the number of EPA increases a contractor may request; and
4. Clarifies that if a contractor has removed an item from their Schedule contract, GSA will
not enforce the limitation on adding the same item back at a higher price.
Economic Price Adjustments

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• Order-Level Materials (OLMs), sometimes referred to as other direct costs, are
incidental supplies, services or costs not specifically identified in a Schedule contract
but necessary for performance of the contract
• 538.72 - Order-level Materials
• “Order-level materials means supplies and/or services acquired in direct support
of an individual task or delivery order placed against an authorized . . . Federal
Supply Schedule (FSS) contract or FSS Blanket Purchase Agreement (BPA) . . .
when the supplies and/or services are not known at the time of Schedule contract
or FSS BPA award. The prices of order-level materials are not established in the
FSS contract or FSS BPA. However, order-level materials are purchased under
the authority of the FSS program . . . and are not open market items….”
-538.7200 Definitions.
Order-Level Materials (OLMs)

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• 552.238–115, Special Ordering Procedures for Acquisition of Order–Level Materials
• OLMs must be in support of an order, not the primary basis or purpose of an order
• Value of OLMs in a task or delivery order or FSS BPA must not exceed 33.33%
• OLMs must be placed under the Order–Level Materials SIN, and prices must include IFF
• Contractors must obtain a minimum of three quotes for each OLM above the simplified
acquisition threshold and, if they cannot get three quotes, must maintain documentation of
why three quotes could not be obtained
• But if the contractor has an approved purchasing system, it is to follow the purchasing
system requirement instead of 552.238-115.
• Contractors may propose indirect costs associated with acquiring OLMs (material handling,
subcontract administration, etc.), provided they do so as a fixed amount (not a percentage of
cost) and include IFF; the CO may request supporting data
Order-Level Materials (OLMs)

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• 552.238–82, Modifications (Federal Supply Schedules)
• Contractors can request to modify Schedule to add or delete products
• Additional items or SINs require CSP and discount information for the new SINs
• Requests for deletion require an accompanying explanation. The Government
“reserves the right to reject any subsequent offer of the same item or a
substantially equal item at a higher price during the same contract period, if the
contracting officer finds the higher price to be unreasonable when compared with
the deleted item.”
• In executing mods, exercise caution in checking boxes indicating that pricing and
discounting remains the same, and only check if you verify to avoid risk of false
certification
Modifications

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• 552.238–83 Examination of Records by GSA (Federal Supply Schedules)
• “The Contractor agrees that the Administrator of General Services or any duly
authorized representative shall have access to and the right to examine any books,
documents, papers and records of the contractor involving transactions related to
this contract for:
• overbillings,
• billing errors,
• compliance with contract clauses 552.238–81, Price Reductions and
• 552.238–80, Industrial Funding Fee and Sales Reporting.
This authority shall expire 3 years after final payment. The basic contract and each
option shall be treated as separate contracts for purposes of applying this clause.”
Schedule Audits and Records

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“Commercial supplier agreements means terms and conditions customarily offered to the public
by vendors of [commercial] supplies or services . . . . intended to create a binding legal obligation
on the end user. Commercial supplier agreements are particularly common in [IT] acquisitions,
including [software] but they may apply to any product or service. The term applies—
(a) Regardless of the format or style of the document. [M]ay be styled as [e.g.] standard terms of
sale or lease, Terms of Service (TOS), End User License Agreement (EULA) . . . may be
presented as part of a proposal or quotation . . .
(b) Regardless of the media or delivery mechanism used; includes Ts and Cs that appear on a
computer[/]electronic device . . . during a purchase, software installation, other product delivery,
registration for a service, [etc.]”
-502.101 Definitions
Commercial Supplier Agreements Terms Incompatible with Federal Law

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• Unenforceable Obligations – where supplies or services are acquired subject to a
commercial supplier agreement, clauses requiring Gov’t to pay future costs and open-ended
indemnification clauses are unenforceable if they would create an Anti-Deficiency Act
violation (31 U.S.C. § 1341). GSAR 552.212-4(u); see also 512.216
• 552.232–78 Commercial Supplier Agreements—Unenforceable Clauses
• Incorporates superseding requires in commercial supplier agreement addressing clauses
incompatible with Federal law.
• Applies “Notwithstanding any other provision of this agreement, when the end user is an
agency or instrumentality of the U.S. Government”
• 552.232-78 takes precedence in the event of a conflict or inconsistency with any other
language, provisions, or clause

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End user Gov’t is the contracting party; agreement cannot bind gov’t employees/agents
Law and disputes Federal law governs and dictates forum/venue and limitations period for disputes
Continued performance Contract may not unilaterally terminate or suspend a contract based upon a suspected
breach of contract by the Gov’t
Arbitration; equitable or
injunctive relief
Binding arbitration only if authorized by agency guidance; equitable/injunctive relief
(incl. attorneys’ fees/costs/interest) only if specified by statute
Updating terms Unilateral revisions to terms after award must be via bilateral mod
Automatic renewal Licenses or services shall not automatically renew upon expiration

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Indemnification Indemnity clauses revised to provide DOJ has sole right to represent the U.S.
Audits Contractor audits of end user compliance must be at contractor’s expense and
cannot be reimbursed by the Gov’t; reimbursement for discrepancies contested
by agency are disputes (i.e., no immediate payment obligation); charges for
discrepancies must follow contract invoice requirements
Taxes or surcharges Taxes/surcharges are governed by underlying gov’t contract, and must be
submitted to the CO for an applicability determination before being invoiced
Non-assignment No contractor assignment except per FAR 52.232–23, Assignment of Claims
Confidential Information Neither agreement nor price list are confidential information; Gov’t may retain
confidential information as required by law (subject to conf. obligation)

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• GSAM Subpart 517.5 - Interagency Acquisitions
• Specifies order of precedence in the event of conflict between the policies of the requesting
agency and the policies of GSA as servicing agency:
(1) Funding agency has a more restrictive policy than GSA. When the customer agency’s policy is
more restrictive, the CO shall follow the more restrictive policy
(2) Higher dollar authority. If requesting agency’s policy is less restrictive, the CO has discretion on
which policy to follow, but choosing the less restrictive policy requires consult with Service-level
acquisition management and the Office of General Counsel to ensure adequate controls
(3) Streamlined approach. Funding agencies require less documentation for certain actions
(4) Specialty program authority. If requesting agencies have authorities GSA does not have, GSA
cannot use the customer agency’s given program authority (e.g., Other Transaction Authority
(OTA)) unless specifically delegated or approved by GSA’s Senior Procurement Executive
Interagency Acquisitions

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• GSAR Part 570 Acquiring Leasehold Interests in Real Property
• GSA’s Public Building Service (PBS) is the primary landlord for the civilian federal
government, responsible for leasing real property. GSA establishes leasing regulations
at GSAR Part 570 under the authority of 40 U.S.C. § 490.
• “Lease or leasehold interest in real property means a conveyance to the Government
of the right of exclusive possession of real property for a definite period of time by a
landlord. It may include operational services provided by the landlord.”
-GSAR 570.102
• U.S. Government acquisitions of leasehold interests in real property are not governed
by the FAR or the other parts of the GSAR or the GSAM, except to the extent
expressly incorporated in GSAR Part 570.
Lease Regulations

SPEAKER
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THANK YOU TO OUR SPEAKER
Daniel H. Ramish
Smith Patcher McWhorter PLC
dramish@smithpachter.com
(703) 847-6300

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