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The General Services Administration (“GSA”) is rolling out two modifications to its Contractor Assistance Visits (“CAVs”), in-person or virtual meetings between GSA’s Industrial Operations Analysts (“IOAs”) and GSA Schedule holders to assess compliance, identify potential problems, and test the contractor’s system controls and processes.  Tom Brady, the Director of the Supplier Management Division, GSA Office of Acquisition Management, presented on these changes during The Coalition for Government Procurement’s webinar on March 12, 2015.

First, GSA will no longer grade contractors on report cards.  GSA’s current practice is to issue a MAS Administrative Report Card following each CAV.  This grade was supposed to reflect how well a contractor was complying with its contract’s terms and conditions.  But contractors had expressed concern that some interpreted the grade more generally to contract performance.  In response to this concern, GSA will discontinue grading its contractors on report cards (and relatedly, commits to providing contractors feedback from the CAV more expeditiously).

Second, CAVs will change from occurring twice during a contract’s life and covering a broad range of topics, to annual visits (at least for those contractors with GSA Schedule sales above $150,000, a threshold that could change going forward), focused on a subset of the topics covering those issues that GSA has determined (through its Office of Inspector General (“OIG”) audits and investigations) are most problematic for contractors.  The subset of topics covers: Basis of Award; Sales; Pricing; Price List/GSA Advantage; and Prompt Payment Discount.  The IOAs will continue to conduct a full compliance review once, at the end of each five-year contract term.

While GSA will continue to use the questions that are on the current version of the CAV questionnaire for the near future, GSA will reassess both the topics and the questions themselves, and is looking to move away altogether from questions that require narrative answers.

GSA is already rolling out this new assessment plan and expects full implementation later this fiscal year.

In response to questions about receipt of unnecessarily burdensome IOA data requests in connection with CAVs, Mr. Brady clarified that representative samples should be sufficient for purposes of a CAV (contrasted with deeper dives by the OIG), and encouraged contractors to work with their IOA to agree upon reasonable sample sets.

As our March 6, 2015 Bullet Point discussed, GSA is proposing to dramatically change the way it seeks to obtain the lowest and best price for items purchased off Federal Supply Schedule and other Government-wide GSA contracts by largely abandoning the Price Reduction Clause (“PRC”) in favor of imposing a requirement that holders of such contracts report, on a monthly basis, specific information on all sales transactions (including unit prices) to authorized users.  Mr. Brady noted that he does not yet know how transactional reporting will affect CAVs, but confirmed that GSA stakeholders are in discussions about the interplay between the CAVs and the proposed changes related to transaction data reporting and PRC monitoring.