The General Services Administration (GSA) is constantly evolving their flagship procurement vehicle, the GSA Multiple Award Schedule (MAS) Contract, to improve efficiency and better meet the needs of federal agencies. From new platforms and requirements, to new Blanket Purchase Agreements (BPAs) and Special Item Numbers (SINs) — it can be difficult to keep track of all the changes that impact GSA MAS Contract holders.
To help you stay informed, we’ve highlighted some of the most significant initiatives we’re tracking in the year ahead, along with who those initiatives impact. Out of all the known changes in the year ahead, the FAS Catalog Platform (FCP) is arguably the most consequential. Continue reading to learn more.
- FAS Catalog Platform (FCP)
- Transactional Data Reporting (TDR)
- New Joint Venture Requirements
- Restructuring of GSA’s Federal Acquisition Service (FAS)
- Proposed Changes to SBA Size Standards Methodology
- Ascend BPA for Cloud Solutions
- Potential New SIN for Credential Service Providers (CSPs)
1. FAS Catalog Platform (FCP)
➥Impacts: All GSA MAS Contractors
The Federal Acquisition Service (FAS) Catalog Platform (FCP) impacts how GSA MAS Contract holders submit modifications. FCP replaces the need to conduct Advantage uploads through the Schedule Input Program (SIP) or EDI-832.
All GSA MAS Contract holders will eventually transition to FCP. However, this year, GSA is transitioning certain product vendors to FCP in small groups. Get up to speed on what FCP here and learn more about the transition process here.
2. Transactional Data Reporting (TDR)
➥Impacts: GSA MAS Contractors with Select SINs who participate in TDR.
If you are not yet familiar with Transactional Data Reporting (TDR), it is an optional program for companies that hold select GSA MAS Contract SINs. In exchange for detailed monthly sales reports, contractors that participate in TDR are exempt from disclosing Commercial Sales Practices disclosures, establishing a Most Favored Customer (MFC)/Basis of Award (BOA), and adhering to the Price Reduction Clause (PRC).
In general, TDR is well received by contractors who opt into the program. On the government side, TDR supports category management goals and the Better Contracting Initiative’s strategy of agency-wide data sharing to achieve savings.
If you hold a GSA MAS Contract that is opted-in to TDR, you should know that GSA plans to make updates to the program later this year. Most of the TDR updates highlighted below are expected out around the third quarter (April-June) of this fiscal year.
FY 2024 TDR Updates
- Real-time validation of sales reporting, data validation of Manufacturer Name, Manufacturer Part Number, Unit of Measure, and Unit Price fields against each contractor’s catalog.
- TDR data quality performance reports, to include “month-over-month summary statistics, rolling counts of issue-based flags, and a view of comparative data quality performance based on Sales Report Portal (SRP) data.”
- Four new TDR fields that may become mandatory at a later date: Order Date, Ship Date, Zip Code Shipped To, and Federal Customer
GSA has long promised the expansion of TDR. However, what started out as a three-year pilot program, is now going on 8+ years. That said, the upcoming TDR field additions are intended to help “prepare new MAS Special Item Numbers (SINs) for the TDR pilot.” So, while plans for TDR expansion have stalled, they are still on the horizon – however distant that may be.
3. New Joint Venture Requirements
➥Impacts: Joint Ventures Awarded a GSA Contract Prior to May 19, 2023
In May of 2023, GSA introduced an official policy with specialized requirements for joint ventures pursuing a GSA MAS Contract. If you are a joint venture who obtained a GSA MAS Contract prior to May 19, 2023, mass modification (mod) A863 requires that you comply with the new JV requirements. This means submitting a modification with the newly required documentation detailed below no later than the release of the Spring 2024 Refresh.
- A JV Solicitation Attachment, and all applicable documents required by the attachment
- A Price Proposal Template (PPT) that identifies which JV partner provides the awarded service
- A draft authorized FSS price list that includes the required JV information/disclosures as well as updated Labor Category and Service Descriptions
It is important to note, you’ll want to submit your mod with the new JV documentation sooner if:
- You have an upcoming extension option; or
- Would like to submit a technical or pricing mod
Need help preparing and submitting your JV documentation? Contact us.
4. Restructuring of GSA’s Federal Acquisition Service (FAS)
➥Impacts: GSA’s Federal Customers & MAS Contractors
The General Services Administration (GSA) Federal Acquisition Service (FAS) serves as the procurement arm of the federal government. Last year, GSA announced plans to restructure parts of FAS beginning in fiscal year 2024.
The plan involves transforming the current 11 region structure, to a more centralized organizational structure. Traditionally, each region would specialize in a specific category of product/service offering. For example, Region 10, based in Washington state was typically responsible for administering GSA MAS Contracts under the Professional Services Large Category. Instead of having multiple teams depending on the buyer’s product/service need, the new structure provides buyers with a central team and more cohesive support.
The GSA Multiple Award Schedule (MAS) Contract falls under the scope of FAS. While contractors may see some impact from the restructuring, that impact should be minimal.
5. Proposed Changes to SBA Size Standards Methodology
➥Impacts: Government Contractors
The Small Business Administration (SBA) is responsible for establishing the size standards used to determine if a business qualifies as “small.” These size standards are important because they determine if a company is eligible for certain set-asides and government contracting programs.
Every five years, SBA is required to review and, if necessary, modify their methodology for determining small business size standards. SBA recently released a whitepaper that details their 5-year review of the 2019 methodology and proposed changes to that methodology. In general, the changes include adjustments to the revenue-based size standards and the adoption of a new methodology to assess the economic characteristics of industries. According to SBA, significant changes include:
- Replacing the current approach to account for the Federal contracting factor with the “disparity ratio” approach. While it is more involved than this, an overly simplified explanation of the disparity ratio is that it involves calculating a ratio, instead of the difference, between the small business share of contract obligations and the small business share of industry receipts.
- Using The Federal Procurement Data System – Next Generation (FPDS-NG) and The System for Award Management (SAM) data to compute the 20th percentile and 80th percentile values of industry factors for evaluating size standards at subindustry levels (“exceptions”), instead of having those calculated based on the Economic Census data
- Updating the minimum and maximum size standard levels.
- Updating the 20th percentile and 80th percentile values of industry factors, derived from the latest 2017 Economic Census and other industry data, used to evaluate the structure of each industry.
These revisions aim to ensure that size standards accurately reflect current economic conditions and provide a fair framework for small businesses to access federal contracting programs. If you’d like to learn more about the revised standards, you can read an in-depth explanation in SBA’s 2023 Size Standards Methodology Whitepaper here.
6. Ascend BPA for Cloud Solutions
➥Impacts: Cloud Service Providers (CSPs)
GSA is taking a step forward with Ascend, a new Blanket Purchase Agreement (BPA) for cloud solutions. The BPA has been in the works for several years now, and activity is starting to pick up. GSA released a Draft Performance Work Statement (PWS) in December of 2023 and held an industry day this week to discuss the BPA’s requirements.
Review a quick background on Ascend here along with a timeline of updates. If your company is interested in competing for Ascend, you can prepare for the BPA by making sure your GSA MAS Contract and offerings under Cloud SIN 518210C are up to date. Contact us for help.
7. New SIN for Credential Service Providers
➥Impacts: Credential Service Providers (CSPs)
In an industry saturated with the use of acronyms, there is bound to be some overlap. We anticipate the new upcoming SIN, 541519CSP, may cause some potential confusion with Cloud Service Providers. However, the CSP in SIN 541519CSP stands for Credential Service Providers (CSPs).
Last year, GSA released a Request for Information (RFI) to obtain feedback on the creation of SIN 541519CSP, Credential Service Providers. The SIN is intended to meet federal agency demands for ID proofing services that are compliant with NIST SP 800-63 Digital Identity Guidelines requirements. RFI responses were due in November of 2023. GSA set aside several one-on-one sessions earlier this year to discuss technical capabilities and pricing models with CSPs.
There is currently no written timeline for the release of SIN 541519CSP, but stay tuned for updates.
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