GSA is transforming the Multiple Award Schedules (MAS) Program to drive better value and save taxpayer dollars. This major transformation will set the stage for a variety of improvements, among them pricing reform through the collection and use of transactional data (i.e., actual prices paid) for Federal Supply Schedule (FSS) contracts and other GSA contract vehicles. This reform will serve as an additional tool for Contracting Officers to evaluate price reasonableness and assist in the overall effort to implement category management across Federal acquisition.
Multiple Award Schedules Transformation – How will the clause be incorporated?
GSA recently issued a Proposed Rule in the Federal Register. We highly recommend reading the Proposed Rule prior to this blog post to get the full understanding of our approach, but here’s a brief summary as it applies to GSA’s Multiple Award Schedules (MAS) contractors to refresh your memory.
The rule proposes a pilot to implement the collection of transactional data for a few select Schedules. Under this pilot contractors would electronically report prices paid for products and services delivered during the performance of the contract (i.e. transactional data) on a monthly basis. In return, these contractors will no longer have to comply with the “tracking customer” requirements of clause 552.238-75 Price Reductions.
We posted a blog already that discussed which Schedules would be included in the pilot and which data elements we intend to collect. We also posted a blog on how the data would be reported by the contractors. For this blog, we want to focus on how the requirements will be incorporated into the contracts.
How would contracts be modified?
For MAS, GSA initially plans to introduce the transactional data reporting requirement with an implementation pilot of five Schedules discussed in a previous blog. The process will begin with issuance of a mass modification through the VSC website. The modification would incorporate a revised clause which will maintain the quarterly reporting of Schedule sales and IFF remittance and implement a monthly reporting of transactional data requirements as outlined in the rule. Currently, our implementation plan anticipates that industry partners will have approximately six months from receipt of the mass modification to begin reporting transactional data.
We need your input. Answers to the following questions would provide tremendous value as we plan to implement the pilot:
We believe utilizing the mass mod process already in place will be the fastest and easiest method of implementing the new clause, but what do you think?
We currently anticipate industry partners needing approximately 6 months after receipt and acceptance of the mass mod to transition from quarterly IFF reporting to quarterly IFF reporting and monthly transactional data reporting. Is 6 months a sufficient amount of time to implement transactional data reporting into your business operations? If not, please provide further explanation.
Generally, contractors have 30 days to review and accept mass modifications. Are there reasons why you would need more time? If so, what are they?
We would appreciate any other comments or input regarding the implementation process.
Please submit all comments directly through Regulations.gov at www.regulations.gov and include GSAR CASE 2013-G504 in your comment. Only comments submitted through regulations.gov will receive a formal response. Comments submitted on the Interact page will be reviewed but may not receive a formal response.
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For 60 years, GSA’s Multiple Award Schedules (MAS) have made it possible for federal agencies to buy smarter. Today, GSA is transforming MAS to enhance this widely used $33- billion a year program to ensure that it continues to offer efficiency and value to both government and Industry. This transformation will include pricing reform.