Quick Tips for Determining Reportable GSA Sales
While being awarded and obtaining a General Services Administration (GSA) Multiple Award Schedule (MAS) Contract may seem like the most difficult part of the process, maintaining contract compliance can often be that much more challenging. Once awarded, every contractor is required to report their contract sales on a quarterly basis. Along with reporting their sales, contractors must also remit payment for associated Industrial Funding Fees (IFF) at that time. In order to do this, it is imperative that contract sales be successfully identified as such and separated from other non-contract sales both governmental and non-governmental. One of the most frequently asked questions contractors usually have is, “What counts as a GSA sale?” Below are some quick tips on how to determine if a sale is reportable under your GSA MAS contract.
What Constitutes a GSA Sale?
A simple rule to remember when determining if a sale is reportable, as described by the GSA Vendor Support Center, is this: “If you are selling a contract item, to an authorized user, at contract prices (or lower), and there is no evidence of another contract vehicle in place, the order is considered a GSA sale.” When evaluating a sale, if one or more of these checklist items are present, then it is probable that this sale is reportable under your MAS contract.
✓ Product or service is on your GSA contract
✓ Pricing is at or below the MAS price
✓ Customer made contact through GSA Advantage! or eBuy
✓ Ordering information and terms are consistent with your GSA contract
✓ GSA contract number is stated on the purchase or task order
✓ Customer pays with a governmentwide commercial purchase card
✓ No other procurement vehicle is being used
What is not a GSA Sale?
It is extremely important to note that open market item sales do not qualify as reportable sales under your MAS contract. Open market items are not awarded under your contract but can be used to fulfil the scope of an order; however, they must clearly be identified as such. Work as a subcontractor is another instance where you would not be able to report those sales, with the exception of specific and rare conditions that fall under Federal Acquisition Regulation (FAR) 51.1. The chart below can be used to help determine whether a sale is indeed a reportable GSA MAS contract sale or not.
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