GSA has taken steps over the past few years to significantly transform one of their flagship purchasing programs, the GSA Schedule. While GSA’s goal is to modernize and simplify the government procurement process, contractors are challenged with keeping up with a multitude of changes. Below, we’ve highlighted a few of the most noteworthy initiatives that could impact contractors over the next year.
Deadline for GSA Advantage MAS Update
A number of companies have not yet updated their GSA Advantage catalog and price list to the new GSA Multiple Award Schedule (MAS) Special Item Numbers (SINs). The deadline for completing the two-step GSA Advantage MAS update is fast approaching. Companies that fail to make the update by March 31, 2021 will have their catalog removed from GSA Advantage, and will also lose access to eBuy.
Who Is Impacted? All companies that hold a GSA MAS Contract that were originally awarded under a legacy GSA Schedule. If your company submitted a proposal prior to October 1, 2019, you would have been awarded under a legacy GSA Schedule.
When? Companies have until March 31, 2021 to take action to avoid having their catalog removed from GSA Advantage.
beta.SAM.gov was launched in the final quarter of fiscal year 2017. Since its launch, beta.SAM has existed alongside SAM.gov while GSA’s Integrated Award Environment (IAE) took steps to merge ten government platforms into one. Later this year, these two platforms will become one as IAE wraps up this multi-year project.
Who Is Impacted? Any entity that does business with the federal government will be affected, as they are required to register and maintain a current registration on SAM.gov.
When? On April 26, 2021, beta.SAM will launch a new look and on May 24, 2021, GSA’s IAE plans to merge the two systems under SAM.gov.
Business Size Standards
Whether or not your company is considered a small business is dependent on SBA’s size standards, which in turn, are dependent upon your company’s North American Industry Classification System (NAICS) codes. Business size standards for some NAICS codes are based upon the number of employees, while other NAICS codes are based upon annual receipts (total income plus cost of goods sold).
SBA is officially changing how they calculate average annual receipts for determining business size status. In the past, NAICS codes based upon annual receipts were calculated using a 3-year average. Starting January 7, 2022 annual receipts will be calculated based upon a 5-year averaging period. For the transition period between January 6, 2020 and January 6, 2022, SBA will allow companies to choose whether they use the 3-year or 5-year averaging period.
When? We are currently in the transition period through January 6, 2022 when the new rule will go into effect.
Transactional Data Reporting (TDR)
Since GSA first introduced the pilot program in 2016, transactional data reporting (TDR) has only been available to companies that hold or pursue select Special Item Numbers (SINs). GSA has been extending the pilot since the original three-year term ended in 2019.
We think that TDR is here to stay, and we hope that GSA decides to make the program permanently available to all GSA MAS Contractors, regardless of the SINs they hold. While TDR is accompanied by additional reporting requirements, it allows contractors to avoid the Price Reductions Clause (PRC) and Commercial Sales Practices disclosure. Transactional data reporting is also a requirement for any contract to be considered a Best-in-Class solution under Category Management.
Who Is Impacted? If GSA extends TDR to the entire GSA MAS Contract, it will impact all current and potential GSA Contract holders. However, for now, TDR only impacts companies that hold at least one of the 63 TDR eligible SINs.
When? We understand GSA is still in the process of reevaluating the program, stay tuned for updates.
MAS Consolidation Plans
In October of 2019, GSA consolidated the 24 GSA Schedules into one GSA Multiple Award Schedule (MAS) Contract. In the final step of this three-phase process, contractors that hold multiple GSA MAS Contracts will consolidate them into one.
Who Is Impacted? Companies that hold multiple GSA Multiple Award Schedule (MAS) Contracts under the same DUNS number.
When? While GSA acknowledges it may take up to ten years for contractors to fully complete their contract consolidation plans, GSA would like all contractors to have their plans in place by the end of fiscal year 2021 (September 30, 2020).
If your company holds multiple GSA MAS Contracts, find out more about your responsibilities in Phase 3 here.
GSA Catalog Management & the Verified Products Portal
Not to be confused with Category Management, which is a government-wide procurement initiative we review here, Catalog Management is a GSA initiative intended to modernize and simplify the buying/selling process for GSA catalog items. As part of the Catalog Management initiative, GSA intends to:
- Create a Verified Products Portal (VPP), “a manufacturer and wholesaler facing portal designed to host authoritative product content, including standardized manufacturer names, part numbers, and specifications.”
- Replace the Schedule Input Program (SIP) that is used by contractors to upload their product catalogs to GSA, with a new web-based application, the Common Catalog Platform (CCP).
Who is Impacted? GSA MAS Contractors will first be impacted in phase 1 of the CCP. Future phases will incorporate companies that hold/maintain GSA BPA catalogs, Retail Operations and 4th Party Logistics, Global Supply Catalogs, and eventually Non-MAS GWACS and IDIQs.
When? There is a multi-year implementation plan for Catalog Management that started in fiscal year 2019 and will continue beyond fiscal year 2022. GSA anticipates issuing a solicitation refresh in April of 2021 that will lay the groundwork for the VPP.