What GSA Contractors Need to Know About Phase 3

MAS Consolidation Phase 3 Update

• Are You Required to Submit a Consolidation Plan?
• Overview & Notes on the Phase 3 Process
• How & When Will You Consolidate to One GSA MAS Contract?
• Get Help Navigating Phase 3

GSA’s multi-year Multiple Award Schedule (MAS) Consolidation plan has officially entered Phase 3. The terminology surrounding the 24 legacy GSA Schedules may remain with us for years to come. However, as of August 1^st, references to the legacy GSA Schedules have been dropped from GSA eLibrary, along with any contractors who failed to accept mass modification A812.

According to GSA, 99% of contract holders accepted mass mod A812. However, many GSA contract holders have yet to complete the accompanying Advantage update. If you only hold one GSA MAS Contract, you have just two remaining actions: 1) update your GSA Advantage text file; and 2) complete the SIP migration. While technically you have until October 31^st to complete these two actions, GSA recommends you submit your updated file by October 1^st to allow enough time for approval.

Welcome to Phase 3

If you hold more than one GSA MAS Contract, you most likely received a Phase 3 welcome email from GSA last week. The email included links to a Phase 3 FAQ and planning checklist. During Phase 3 of the MAS Consolidation, most companies that hold more than one GSA MAS Contract under the same DUNS number are required to create and implement a plan to reduce their contracts down to a single contract.

We should note, not all companies that received a Phase 3 welcome email are required to submit a contract consolidation plan in Phase 3. If you hold two GSA MAS Contracts and one is a follow-on contract that mirrors your other contract, you are not considered part of Phase 3 and do not have to submit the checklist provided in the Phase 3 welcome email. During a webinar earlier this week, Stephanie Shutt, Director of the MAS Program Management Office (PMO), explained that contractors fitting this scenario were included in the welcome email because GSA felt the checklist provided beneficial information. Companies with a follow-on contract can use the checklist questions to help determine when to off-ramp and cancel their old GSA Contract.

Are You Required to Submit a Consolidation Plan?

It’s important to first determine if your contracts are part of Phase 3. You are not included in Phase 3 if you only hold one GSA Multiple Award Schedule Contract; VA Schedule Contracts and GSA Contracts outside of the MAS program (OASIS, ALLIANT, EIS, VETS, Connections, 8ASTARS) do not count. If you hold multiple GSA MAS Contracts and meet all the requirements below, you are included in Phase 3 and are required to submit a completed checklist and consolidation plan to GSA.

1. You hold multiple GSA Contracts under the same DUNs number.
2. You hold multiple GSA Contracts where two or more 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.
3. You hold multiple GSA Contracts where two or more are not considered a follow-on contract.
4. You have accepted mass mod A812 for each GSA MAS Contract you hold.

Overview & Notes of the MAS Consolidation Phase 3 Process

• Determine if your company is part of Phase 3.
• Review the Phase 3 Overview/FAQ document and Checklist you received from GSA. GSA would like companies to prioritize supporting their customers, particularly considering the Q4 buying season. However, they also ask that you take some time over the next month to review the Phase 3 documentation.
• If you have an expiring contract or an opportunity coming up that requires an immediate need to move forward with a Phase 3 consolidation plan you should communicate this with your Procurement Contracting Officer (PCO) as soon as possible.
• Wherever possible, GSA will reassign Phase 3 companies to one PCO. Most transfers will occur between now and the end of the calendar year (Q4 of FY 2020 to Q1 of FY 2021).
• Be on the lookout for emails from your current PCOs and promptly respond to any requests to avoid delays in being transferred to one PCO.
• If you do not have any time sensitivities, GSA recommends you wait until you are assigned to a single PCO before you submit your completed checklist and move forward with Phase 3.
• If your contracts cannot be assigned to a single PCO or you cannot wait to be transferred, you will need to submit your completed checklist to the PCO for each GSA MAS Contract you hold.
• All Phase 3 contractors should submit their checklist and consolidation plan by August of 2021. Full implementation of your plan may take 5 to 10 years if you have BPAs attached to any of your GSA MAS Contracts.

In order to participate in Phase 3, companies must accept mass mod A812 for each GSA Schedule Contract they hold. If you have not accepted the mass mod for one or more contracts because those contracts are expiring or have low to no sales, GSA suggests that you confirm there are no open orders or Blanket Purchase Agreements (BPAs) against the contracts and then consider initiating their cancellation. You can eliminate the need to report sales and maintain compliance by cancelling unnecessary contracts.

How & When Will You Consolidate to One GSA MAS Contract?

Your company will ultimately decide when and how you consolidate to one GSA MAS Contract. As we mentioned previously, your plan is due by August 2021, however implementation and completion of your plan may take up to 10 years.

Companies that are part of Phase 3, will generally have the following options to achieve one GSA MAS Contract:

1. Select a surviving contract and submit modifications to add the products and services from your other GSA MAS Contracts to the surviving contract. This can be achieved through a series of contract modifications or one bulk Special Item Number (SIN) addition modification.
2. 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.
3. Start from the beginning; submit a proposal to obtain a new GSA MAS Contract and then cancel all previously held GSA MAS Contracts.

During the webinar this week, Stephanie Shutt reaffirmed there is no streamlined modification process to add products and services from an existing GSA MAS Contract to another contract. She did however share that GSA is considering ways to simplify the modification process for Phase 3 contractors. She also indicated the possibility of a simplified process was another reason why companies should wait until they are assigned to one PCO to move forward with a consolidation plan.

You can find more information on Phase 3 of the MAS Consolidation, including the Phase 3 Overview/FAQ and Checklist, on GSA interact here.

Get Help Navigating Phase 3

FEDSched has been helping companies manage their GSA Schedule Contracts and understand the impact of GSA changes for more than 30 years. Contact us if you’d like additional assistance developing and implementing your Phase 3 consolidation plan. You can also subscribe to our newsletter and alerts to stay up to date on the latest information.