It usually starts off with an email from someone at GSA, that begins, “As part of your GSA schedule contract requirement, I would like to set up a Contractor Assistance Visit (CAV) review with you on ___.”
A pit forms in the base of your stomach, but then subsides because you convince yourself you have all your ducks in a row when it comes to compliance with your GSA Contract. Or are you?
That night, your subliminal fears awaken when you might have a dream, not unlike the following:
Okay, hopefully you won’t have a dream quite like the above, as this video represents a dire situation in which the fictional firm had few if any management controls in place to properly administer their GSA contract. The firm also seemed poorly prepared when answering many of the most important questions that GSA asks. What are the most important topics GSA inquires about?
During a GSA CAV, you will need to demonstrate or know the following:
- Are you selling only services or products that fit within the scope of the SINs in your contract?
- Did you properly identify items not on your contract as open market items to your federal customers?
- Were all your products and services in compliance with the Trade Agreement Act (TAA)?
- Did you properly and promptly update GSA Advantage!® after modifications?
- Did you properly identify, track and report GSA sales accurately and completely?
- Are you meeting the minimum contract sales requirement under your contract ($25,000/year)?
- Do you monitor the "BASIS OF AWARD" customer discount relationship? This is a big area of concern and source of too many problems.
- Did you charge customers the correct GAS contract price (or lower)?
- When changes occurred that required a modification, did you properly initiate a modification? (For example, following a company change of name or novation)
- If you are a large business, did you properly file subcontracting plan reports and are you meeting plan goals?
More about GSA Contractor Assistance Visits
First a caveat. GSA does not send out an auditor to conduct a GSA Audit. GSA uses the term “Industrial Operations Analyst” to conduct “Contractor Assistance Visits.” Yes, that sounds a lot like, “we are from the government and we are here to help,” and many consider these terms a euphemism for an auditor doing an audit. Regardless, you should treat these CAVs very seriously as the results can have a major impact on the continuation of your contract.
CAVs are typically conducted twice during a five-year contract term. The first occurs about 6-18 months into your contract, and then generally 42-48 months into your contract. The first audit is done primarily to make sure you understand the contract terms and have a process in place to properly administer the contract. The later audit tends to focus on compliance and deficiencies can have serious consequences. Failure to meet GSA requirements can result in:
- loss of contract
- adjustment of pricing
- claims for recovering funds
Following each CAV, GSA will issue a MAS Contractor Assessment Initiative Report Card, or simply, a Report Card. If any critical element is deficient, it is considered grounds for cancellation or non renewal at the end of your contract period.
What Should You Do to Prepare for a GSA CAV Audit?
- GSA Schedule Contract Document Management
- Receiving a GSA Schedule Order
- Price Reduction Clause Issues
- Economic Price Adjustment (EPA) Issues
- Government Billing Process
- Proper Industrial Funding Fee payments
- How you train staff about contract terms and compliance
- Use of GSA's eTools
- Related GSA Schedule marketing issues
Properly preparing for a CAV can help you avoids lots of headaches.
So as we write this, we are perplexed that no academy award nominations for best short film have been received for our video. But, we hope it helps ease your fear of a GSA audit and moves you to take steps now to ensure compliance with your GSA contract.
UPCOMING WEBINAR DATES: