Dec 8, 2016

GSA OIG Reviews Industrial Operations Analysts:  What's In Your IOA’s Report Card? | Centre Law & Consulting in Tysons, VA
 
As a consultant assisting clients prepare for their Industrial Operations Analyst (IOA) visit, I am surprised by the anxiety that precedes these “I’m here to help you” visits. I receive comments from “I didn’t sleep all night” and “I forgot my Basis of Award (BOA) customer” to “Will the IOA cancel my contract as I forgot to pay my Industrial Funding Fee for the last quarter.” The anxiety has increased over the last two years as the IOAs are now reviewing your GSA Schedule annually if you have annual sales exceeding $150,000. While the majority of IOAs are trying to help you understand compliance with your schedule requirements, there are a few that want to add to your anxiety. I witnessed the IOA who started the visit with the comment that she was there to get money back for GSA and an IOA who threatened cancellation of the schedule (and no, IOAs cannot cancel your schedule contract).

In GSA’s Office of Inspector General (OIG) Semiannual Report to Congress for the period of April 1, 2016 through September 30, 2016, the tables were turned and the IOAs were reviewed.

IOA Assessment Report Purpose

The OIG conducted an audit of the contractor assessments program to determine if:

  1. Contractor assessments were effective to determine contractors’ compliance with schedule contract terms and conditions
  2. IOAs were conducting their assessments in accordance with FAS guidance
  3. IOAs were communicating those results in a timely fashion and in the appropriate format
  4. IOAs were developing and completing training in accordance with program requirements

 

IOA Assessment Report Findings

As a result, the OIG concluded the following:

  1. Assessments add value as a method to monitor contractor compliance with terms and conditions of schedule contracts
  2. IOAs are generally conducting assessments in accordance with guidance
  3. OAs are effectively communicating those results in a timely fashion and in the required format

 

IOA Assessment Areas of Improvement

The OIG also concluded that although the assessments were generally effective, they identified areas that could be improved “to enhance the consistency, completeness, and value of the assessments and reports.” For example:

  1. FAS guidance does not provide specific requirements for sampling schedule sales transactions to ensure that contractors are properly reporting and remitting Industrial Funding Fees and resumes to verify that qualified labor for services are being provided for customer agencies.
  2. IOAs are not consistently reporting on labor qualifications. As a result, FAS does not have assurance that labor qualifications were assessed.
  3. FAS has not established a formalized, national training curriculum for experienced IOAs.

 
Therefore, recommendations from the OIG to the FAS Commissioner include:

  1. Revising the IOA Training Manual to include details on a risk-based sampling methodology
  2. Revising the assessment report template to include a specific section for reviewing labor qualifications to ensure consistent assessments
  3. Establishing and implementing a formal national training curriculum for experienced IOAs

 

What Can I Do?

In summary, Contract Clause 552.215-71 (Examination of Records) allows the IOA to review contractors’ records to verify contractual compliance. Their role is to conduct contractor assessments as well as monitor sales reporting, sales adjustments, and Industrial Funding Fee remittance (previously conducted by your Administrative Contracting Officer).

Remember that the results of the IOA visit are advisory to your Contracting Officer (CO). Their assessment will be included in your GSA file for review prior to your Option Renewal. If you receive a negative assessment or don’t agree with a finding, you should submit a letter of clarification to your CO.

The best thing you can do to in advance of your IOA visit is to be prepared. Gather all documents requested by your IOA prior to the visit or virtual call. Review the terms and conditions of your schedule and know your Basis of Award and discounting. Ensure your GSA Schedule catalog is up to date and matches the last awarded modification. If you stay compliant with the requirements of your Schedule, then you will have a successful IOA review.

Your IOA contact information can be found at https://vsc.gsa.gov/tools/aco_ioa.cfm and Centre’s GSA Consultants are available to assist you through the process as well.

About the Author:

Maureen Jamieson | Centre Law & Consulting Maureen Jamieson
Executive Director of Contracts and Consulting

Maureen Jamieson has more than twenty-five years of experience managing federal contracts. She is highly experienced in solving client pricing problems and implementing effective pricing strategies for placing products and services on GSA Schedule contracts.

 

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