On June 13th, the General Services Administration (GSA) sent out an e-mail to all GSA Contract holders notifying them that a mandatory modification for manufacturer part numbers (A382) would be released on June 17th. The stated purpose of the mass modification was to reinforce the requirements of clauses I-FSS-600 Contract Price Lists (Oct 2013) and GSAR 552.238-71, Submission and Distribution of Authorized FSS Schedule Price Lists. For uncertain reasons, by June 20th GSA had notified GSA Contractors that the mass modification was postponed and would be released at the end of June. It is now July 24th and there is no sign of the mass modification. From what we’ve heard, the new projected release date is now sometime in late August.
Now, you may be wondering why all of a sudden GSA feels the need to reinforce these administrative clause requirements, but if you’ve been keeping up with the whole “fair and reasonable” and “competitive” pricing re-evaluation going on in the GSA world, this should come as no surprise. GSA is now using a software called XSB Price Point, which allows Contracting Specialists and Officers to easily pull a report that shows how competitive a Contractor’s proposed pricing is by doing a horizontal pricing analysis. The way that the Price Point software identifies competitive pricing for products is by the manufacturer part number, which explains why GSA is releasing this mandatory mass modification. Without the correct manufacturer part number, the Price Point software will not work as intended. The data found in the report generated by Price Point is pulled from various government websites such as GSA Advantage!, DOD EMALL, Reverse Auction websites, etc. Price Point also provides links to external commercial pricing sources, including Amazon and Google.
The good news about the mass modification delay is that GSA Contractors can be proactive and get a head start updating their GSA Advantage! Price Lists and SIP files to ensure that they are compliant. Once the mass modification is released, GSA Contractors will have 90 days to review and accept the modification, as well as respond to the questions in the modification and update their GSA Advantage! Price Lists and SIP files. Failure to comply with the terms of the modification may result in contract cancellation.
When updating your GSA Advantage! Price List and SIP files, please keep the following in mind:
- Do not alter the manufacturer part numbers. For example, GSA Contractors should not add their own prefixes or suffixes to any manufacturer part number or use their own internal SKUs.
- If you do not have manufacturer part numbers, you should contact the manufacturer immediately and request they send them to you.
- Include the manufacturer part numbers in your GSA Advantage! Price List.
- All awarded services, products, ancillary products, etc… should be included in your GSA Advantage! Price List.
- All products should be included in your SIP files and uploaded into GSA Advantage!
Although this modification isn’t really applicable to GSA Contractors who only provide services under their GSA Contract, they are still required to accept and respond. This would also be a good time to ensure that your GSA Advantage! Price List is up-to-date per your latest modification.
Here are some frequently asked questions (FAQs) provided by GSA:
1: Is this mass modification mandatory?
A: Yes. This mod is mandatory to ensure GSA is capturing all the Manufacturer Part Numbers and all other descriptive data for all Products awarded on the GSA MAS contract, including Ancillary Products and fixed-price services (i.e. training course).
2: I have a service only contract, and have no fixed-price services or ancillary products. How do I respond?
A: Although the reinforcement is not applicable to your contract, select “yes” to acknowledge the requirement.
3: Do I need to submit all my products?
A: Yes. Any product, ancillary product, or fixed-price service that you have listed on your MAS contract should be submitted, along with its corresponding product data.
4: Does this rule apply to previous submissions?
A: Yes. Industry partners should take this opportunity to revisit previous submissions and correct/refine any missing or altered manufacturer part numbers.
5: What should I do if I do not have (or cannot obtain) the Manufacturers Part Number?
A: Industry partners should make a best effort to obtain accurate product information.
6: Why is GSA asking for Manufacturer Part Numbers?
A: GSA is focusing on bolstering data driven offerings in order to improve the acquisition experience for customers, acquisition officials, and industry partners alike. Expanded data repositories pave the way for streamlined, value-added functionality that will minimize effort while maximizing returns.
NOTE: In an email sent to Schedule holders the evening of July 23rd, GSA issued further guidance regarding part number standardization efforts and hinted that UPCs may be the next big data requirement for this initiative. Stay tuned to Centre Knowledge for more on this breaking story next week!