My colleague, Candace Clokey, wrote a blog last week regarding the General Services Administration’s (GSA) recent e-mails notifying GSA contract holders of a forthcoming mandatory modification requiring that all products on FSS Schedule be assigned a manufacturer part numbers (A382). We are hearing the new projected release date for the mass mod will be in late August. In addition, GSA has notified GSA contract holders on another initiative for improving product number data quality on GSA Schedules. In the e-mail, GSA is seeking collaboration with industry partners to help improve the quality and utility of product data information available on GSA Advantage. The anticipated outcome of this effort is to provide agencies with great visibility into the comparability of products offered through the FSS program.
For contractors who primarily offer products, GSA is seeking contract holders to help in improving the integrity of the schedule offerings by submitting Universal Product Codes (UPC) and Manufacturer Part Number (MPN) for each awarded contract item. GSA believes this can yield numerous advantages to the Schedule holder, such as:
- Increased business from federal, state, and local government buyers who are looking for standard Universal Product Codes (UPC) to make accurate product comparisons through a quick search
- Increased visibility from government buyers by reducing the number of redundant product search results
- Compliance with the requirements of clause I-FSS-600 Contract Price Lists (Oct 2013), 552.238-71, Submission and Distribution of Authorized FSS Schedule Price Lists, & SCP-FSS-001 Instructions Applicable to All Offerors (March 2014)
The GSA’s goal is to strengthen agencies’ ability to find you on GSA Advantage and also ensure that your contract is in compliance with the requirements of clause I-FSS-600 Contract Price Lists (Oct 2013) and 552.238-71 Submission and Distribution of Authorized FSS Schedule Price Lists. Per the clause, price lists (catalog files) must be complete and include all supplies, prices, and terms and conditions that were accepted by the Government at award and should include accurate product descriptive data. Base products are considered the basic model without any options or accessories.
Furthermore, GSA is using this data to engage in more aggressive price evaluation of FSS product offerings, through the use of software called XSB Price Point, which as our colleague mentioned in her prior blog, allows Contracting Specialists and Officers to pull reports that show how competitive a Contractor’s proposed pricing is by conducting a horizontal pricing analysis. The Price Point software identifies products by the manufacturer part number, which is why GSA is releasing mandatory mass modification A382. The end result is that GSA reserves the right to reject new product offerings (both new proposals and modifications) where it determines that the offered prior is not competitive with other pricing available to federal buyers either through the FSS program or elsewhere. So please be forewarned that GSA will be using the new information you provide to validate that your prices going forward are deemed both fair and reasonable and highly competitive.
GSA’s notice regarding UPC codes are part of the number standardization efforts but is not fully required yet by GSA. If UPC is not available for all your products, GSA requests contract holders to make an effort to obtain the UPC from the manufacturer and provide that UPC as part of your data upload. If a product does not have UPC, make sure to have the Manufacturer Part Number (MPN) as required. Uploads of all base product contract line items with UPC and MPN to GSA Advantage via SIP within 90 days after the mass modification is released.
For service and product vendors, we recommend that you review your GSA Advantage Price List and ensure you are up-to-date with the new requirements as the mass modification is applicable to both product and services offerings. Especially for product vendors with thousands of products on Schedule, we encourage you to go through your awarded products to ensure you have Manufacturer Part Numbers and/or UPC codes.