GSA is taking steps to make it easier for companies that offer products or services that support COVID-19 response efforts to qualify for a GSA Contract. In the final days of February, GSA quietly posted Acquisition Letter MV-21-03 regarding a temporary waiver of certain GSA Multiple Award Schedule (MAS) Contract requirements.

The GSA MAS Contract streamlines the procurement process, allowing government buyers to quickly purchase the supplies and services they need. The temporary waiver is designed to expand the availability of supplies and services on the GSA MAS Contract that meet COVID-19 demands. By reducing contract requirements, GSA will allow more companies to qualify sooner than they would have under normal circumstances.

Acquisition Letter MV-21-03 & Supplement 1

Acquisition Letter MV-21-03 established GSA’s intention of waiving certain requirements in an effort to better meet government COVID-19 needs. However, the letter was short on specifics and led to a number of questions regarding applicability and implementation. In late March, GSA issued a Supplement to clarify the Acquisition Letter:

• Does not apply to non-COVID-19 related offerings
• Authorizes MAS Contracting Officers to award MAS contracts and modify existing MAS contracts to add service SINs that directly support the COVID-19 response
• Does not diminish a MAS Contracting Officer’s overarching responsibilities (i.e. determining fair and reasonable pricing and ensuring compliance with solicitation
  requirements)

What Requirements Are Waived by MV-21-03?

GSA is waiving the three requirements detailed below for products, services, or solutions that directly support the government’s response to COVID-19:

• Two years of corporate experience
• Relevant project experience for each SIN proposed
• Previous two years of annual financial statements

COVID-19 GSA Contract Waiver Details

While the Acquisition Letter Supplement addressed a few questions, many questions remained open until GSA issued a post on Interact last week. The post included additional information, as well as a list of frequently asked questions to help companies better understand how the waiver will be applied and implemented.

The FAQ states that any proposal or modification submitted under the waiver can only include offerings that directly support COVID-19 efforts. Proposals and modifications that include additional, non-COVID related products or services will be rejected. The FAQ also clarifies that while the waiver is temporary, any GSA MAS Contract awards made under the waiver will not be cancelled when the waiver ends.

Does the Waiver Apply to All GSA SINs?

• The waiver applies to all Large Categories, Subcategories, and Special Item Numbers (SINs) under the GSA MAS Contract, provided the product/service/solution directly supports COVID-19 response efforts
• The waiver does not apply to any of the VA Schedule Contracts

Upcoming Solicitation Refresh 6 Will Include COVID-19 Waiver Language

Next month, GSA plans to issue refresh 6 of the GSA Multiple Award Schedule Solicitation. The refresh will formally incorporate a number of changes in the GSA MAS Contract, including language regarding the temporary waiver of certain requirements to support the COVID-19 response.

Additional COVID-19 Support Initiatives

As noted within the Interact Post, this waiver is one of several actions GSA has taken to support the government’s COVID-19 response efforts. Previous actions include a temporary exception to the Trade Agreements Act (TAA) for specific products, as well as the temporary suspension of contract cancellations due to low sales.

Does Your Company Provide Supplies or Services That Could Support COVID-19 Response Efforts?

Our team here at FEDSched has been helping companies obtain and manage their GSA Contracts for more than 35 years. We can help you assess eligibility and quickly prepare a proposal or modification under the COVID-19 waiver.