You no doubt have heard by now about GSA’s 23 June effort to “embrace modern technology while moving away from outmoded practices” – specifically, its implementation of the new Transactional Data Reporting Rule (“TDR Rule”) and its concurrent elimination of the Price Reductions Clause (“PRC”) and the Commercial Sales Practices Format (“CSPF”). See 81 Fed. Reg. 41104 (June 23, 2016). The new rule covers certain GSA Multiple Award Schedules as well as the Agency’s GWAC and IDIQ contracts. As it represents the most significant change to the GSA MAS program since 1994 (when GSA removed federal sales as a PRC trigger), the new rule has the potential to change significantly the way Schedule contractors (and others) do business; hence, my willingness to interrupt your otherwise enjoyable day with a treatise on GSA Schedule contracting.
Continue Reading Price Reductions Are Dead; Long Live Price Reductions
Office of Inspector General
The DoD IG Has Moved
The Office of the Inspector General of the Department of Defense recently changed its mailing address. Unfortunately, some contractors have failed to notice the change, and have used the old address in attempting to submit their disclosure letters. Unfortunately, these disclosures were returned to sender. The new address(es) are below, and detailed information can be found here. For further information regarding the mandatory disclosure rule, please see our previous posting on the ABA’s Guide to the Mandatory Disclosure Rule or an article authored by two of our government contracts partners, Louis D. Victorino and John W. Chierichella, republished with permission from The Government Contractor.Continue Reading The DoD IG Has Moved
From Attestation Reviews To Examinations: The GSA OIG Expands The Scope Of Its Pre-Award Audits
So there I was, just sitting there minding my own business. It was the third day of the GSA OIG’s site visit being conducted as part of a routine pre-award audit (or as the OIG called it, a pre-award “attestation review”), and all was going well. The auditor, who was quite a nice guy frankly, had had many questions, as was to be expected, but nothing for which this particular mid-sized GSA Schedule contractor did not have a reasonable response. No Price Reductions Clause violations. No overbillings. No resume qualification issues. Overall, a pretty darn good preliminary report if you ask me. But then, out of the blue, he says, “okay, I’d like to interview your personnel now.” Interview my personnel?! Come again!?
Continue Reading From Attestation Reviews To Examinations: The GSA OIG Expands The Scope Of Its Pre-Award Audits