MANAGING A GSA CONTRACT

GSA MAS Contract Administration and Compliance Checklist

MAS contract administration is the routine work of staying compliant: reporting sales monthly through the FAS Sales Reporting Portal, remitting the Industrial Funding Fee (IFF) at least quarterly, keeping the contract current in eMod, and following the clauses in your contract. Use this checklist as a starting point, and confirm anything that applies to your contract with your contracting officer.

What are the core MAS obligations?

Sales reporting under TDR

Contractors report sales made under the contract through the FAS Sales Reporting Portal (SRP), at line-item detail, monthly. Reports are due within 30 days after the end of the month, and months with no sales are confirmed as zero-sales. The older quarterly 72A process has been replaced.

Industrial Funding Fee

The IFF is 0.75 percent of reported sales. Contractors remit it at least quarterly, within 30 days after the quarter ends, through Pay.gov. Monthly remittance is allowed. The IFF is built into your contract prices. See TDR and the Industrial Funding Fee.

Modifications

Use eMod for changes to your offerings, pricing, and information, and to accept GSA mass modifications. Do not sell items or services outside your awarded SINs.

Examination of records

GSAR 552.238-83 provides for the government to examine records related to the contract for three years after final payment. Keep organized invoices, pricing records, and sales data.

Minimum sales

The solicitation sets minimum sales criteria, generally $100,000 in the first five years and $125,000 in each later five-year period. Inactive contracts can be cancelled.

Catalog and offering upkeep

Keep offerings current in GSA Advantage, eLibrary, and eBuy using the FAS Catalog Platform where applicable, and publish updates within the timeframe your contract specifies, generally 30 days.

What laws and clauses come with the contract?

Your award incorporates many clauses. Which ones apply depends on your offering, size, and the SINs you hold. Common examples include:

• Trade Agreements Act requirements for covered products. See Trade Agreements Act Compliance.
• Service Contract Labor Standards for covered service contracts
• Equal opportunity and related labor clauses
• Subcontracting plan requirements and reporting for large businesses through eSRS
• Requirements added in refreshes, such as recent executive order-related clauses and environmental product clauses
• Veterans employment reporting where applicable

Do not assume a clause applies or does not apply based on a list. Read your contract, and ask your contracting officer for help when needed.

What should be in your compliance calendar?

What triggers audits or reviews?

GSA may review contract compliance, including sales reporting, pricing, and TAA. A contracting officer or industrial operations analyst may contact you. Keep your records ready and respond promptly. Do not treat a review as a surprise. Treat it as a routine part of doing business under the contract.