Update 3/15/2022: Phase 3 Checklists are now due on April 30, 2022.
Update 9/23/2021: Phase 3 Checklists are now due on December 31, 2021; extended from September 30, 2021.
Less than two years ago, GSA introduced the single GSA Multiple Award Schedule (MAS) Contract as part of Phase 1 of the plan to consolidate the 24 GSA Schedules into one. In January of 2020, GSA began Phase 2, which involved transitioning legacy GSA Contract holders to the new, single GSA MAS Contract. In the third and final Phase, which began in August of 2020, companies that hold multiple GSA MAS Contracts are responsible for pairing down to one contract.
What You Need to Know About Phase 3 of the MAS Consolidation
- Phase 3 only impacts companies that hold more than one GSA MAS Contract. If you hold just one GSA MAS Contract, your responsibilities regarding the consolidation were met when you completed the two-step GSA Advantage MAS Update, which was due March 31st of this year.
- Not all companies that hold more than one GSA MAS Contract are part of Phase 3, see the qualifications in the section below.
- If you company holds multiple GSA MAS Contracts and is considered part of Phase 3, you are required to submit a MAS Phase 3 Contractor Checklist that includes a plan to consolidate your contracts into one contract.
- GSA has said the Phase 3 Checklists and Consolidation Plans are due by
September 30December 31, 2021. However, we are seeing some GSA Contracting Officers request this information now.
- While your Consolidation Plan must be submitted by
September 30thDecember 31st, the process of consolidating your contracts may take up to ten years depending on BPAs.
Is Your Company Part of Phase 3?
If you meet all of the criteria below, your company is most likely part of Phase 3. This means you are required to submit a Phase 3 Contractor Checklist and Plan to consolidate your contracts into one contract.
- You hold multiple GSA MAS Contracts under the same DUNs number (VA Schedule Contracts are excluded).
- Two or more of your GSA MAS Contracts are not classified as a small business set-aside (SBSA) contract. If you only hold two GSA MAS Contracts where one contains SBSA Special Item Numbers (SINs) (these are noted in eLibrary) and one does not contain SBSA SINs, you must keep these contracts separate.
- Two or more of your GSA MAS Contracts are not considered a follow-on contract. For example, if your company holds two GSA MAS Contracts, but the newer contract is intended to replace the expiring contract.
Benefits of Consolidating Your GSA Contracts
While it will take some effort to consolidate your contracts, you should benefit in the long run from reduced contract administration. Post-consolidation, you will only have to report sales, remit IFF, manage contractor assessments, and handle renewals for one contract. If your company has one GSA MAS Contract participating in Transactional Data Reporting (TDR), you have extra incentive to streamline down to a single, TDR eligible contract. View Five Benefits of the Consolidated GSA MAS Contract.
Phase 3 MAS Consolidation Plan Options
Last August, as part of a larger overview of Phase 3, we highlighted the core options companies have to consolidate their contracts. The three paths to contract consolidation include the following options:
- Select a surviving contract and submit modifications to add the products and services from your other GSA MAS Contracts to the surviving contract; or
- Select a surviving contract and cancel all other GSA MAS Contracts if they have low sales and/or no longer represent your company’s core offering; or
- Start from the beginning; submit a proposal to obtain a new GSA MAS Contract, then cancel all previously held GSA MAS Contracts.
Selecting a Surviving Contract
Unless you choose to start over and obtain a new GSA MAS Contract, you’ll need to select a surviving contract when you complete the Phase 3 Checklist and Consolidation Plan. This is an important decision that warrants careful consideration.
There are several factors to consider, and the best approach will vary based upon your circumstances. While the remaining period of performance may be the deciding factor for one company, it may not be the best option for your company. When determining your surviving contract, weigh the importance of the factors below in conjunction with your company’s goals and priorities.
Surviving Contract Evaluation Factors
- Remaining Period of Performance
- Contract Sales
- Number of Special Item Numbers (SINs)
- Participation in Transactional Data Reporting (TDR)
- Pricing Structure (to include discounts and escalation)
- Blanket Purchase Agreements (BPAs)
After submitting your Phase 3 Checklist and Consolidation Plan to GSA, you’ll start the potentially time-consuming modification process to add the SINs and offerings from your non-surviving contract(s) to the surviving contract. Once all of your products and services are migrated to the surviving contract, you should review any open orders or BPAs and determine a cancellation date for the non-surviving contract(s).
How to Prepare for Phase 3
If you have time before you begin the consolidation process, conduct an assessment of your GSA MAS Contracts. Make updates as needed to ensure your GSA Contracts are current and accurate. Beyond complicating the consolidation process, an outdated contract can cost you sales.
Phase 3 Pre-Consolidation Checklist
- Confirm you’ve completed the required Advantage MAS Update
- Check for outstanding mass modifications on each of your GSA MAS Contracts
- Ensure the following GSA MAS Contract items are current and accurate:
- Terms and conditions
- Products and/or Services
- Administrative Points of Contact
- GSA Advantage Catalog
- Confirm sales reports and Industrial Funding Fee (IFF) submissions are current and accurate
- If needed, update your System for Award Management (SAM.gov) registration
- If applicable, resolve any findings from Industrial Operations Analyst (IOA) Contractor Assessments
Need Help With Your Phase 3 Plan & Contract Consolidation?
FEDSched has been helping companies obtain and manage their GSA Contracts for over 35 years. We’ve been closely following the GSA MAS Consolidation since it was first announced years ago. Our contract experts can help you develop and execute a customized plan for consolidating your contracts into a single GSA MAS Contract. You can also subscribe to our newsletter and alerts to stay up to date on the latest information.