Mar 30, 2017

No April Fools Joke: GSA Refresh/Mass Mods Are Coming | Centre Law & Consulting in Tysons, VA
The General Services Administration (GSA) Federal Acquisition Service (FAS) is planning to refresh ALL Multiple Award Schedules (MAS). The purpose of the refresh is to incorporate provision and clause changes into MAS solicitations and contracts. Be on the lookout for updates tentatively planned for April 2017.

Major changes to the Small Business Subcontracting Plan will be included in these Refreshes/Mass Mods that will impact both large and small businesses. Look for changes in the Model Subcontracting Plan that reflect additional requirements. These changes were effective November 1, 2016 when DoD, GSA, and NASA issued a final rule amending the Federal Acquisition Regulation (FAR) to implement changes made by the Small Business Administration.

Key changes of the refresh and mass modifications are as follows:

Small Business Subcontracting Plans:

Large Business Prime Contractors Must:

  • Make good faith efforts to utilize their small business subcontractors during the contract term to the same degree the prime contractor relied on the small business in preparing and submitting its bid or proposal
  • Resubmit a revised subcontracting report within 30 days of receipt of a notice of report rejection
  • Assign North American Industry Classification System (NAICS) codes to subcontracts
  • Not prohibit discussion of payment or utilization matters between a subcontractor and the contracting officer
  • Report order level subcontracting information if prime has a subcontracting plan on task and delivery order contracts after November 2017*

Contracting Officers May:

  • Require a subcontracting plan after a small business re-represents its size as other than small
  • Necessitate subcontracting goal calculation in terms of total contract dollars** as well as in terms of total subcontracted dollars

Updates to Non-Federal Entities Purchasing off Federal Supply Schedules (FSS):

  • The State/Local Disaster Purchasing Program*** extends to cover disaster preparation and response as well as recovery from major disasters
  • Access extends to certain qualifying organizations including the American National Red Cross and National Voluntary Organizations Active in Disaster

Revisions to I-FSS-600 Contract Price Lists:

  • Requirement for submission of contractor’s electronic files is updated to no later than 30 days after award

Other Changes:

  • Removal of Pathway to Success training requirement for streamlined (Successful Legacy) offers
  • Updated Service Contract Labor Standards Act (SCLS) Wage Determinations (WDs) to be added to all schedules
    • Contractors to ensure pricing and WD references are updated and included in SCA matrix

For the latest proposed draft updates, see more on GSA Interact.

* Requirement date may be extended as updates to the Electronic Subcontracting Reporting System (eSRS) are ongoing.
** Offeror may include a proportional amount of products and services that are ordinarily allocated as indirect costs.
*** Disaster Purchasing Program participation is voluntary and vendors may opt in or out at any time during their contract term.

About the Author:

J. Moore

J. Moore is a GSA and VA Contract Consultant at Centre Law & Consulting. She collaborates with the consulting team to provide proposal and contract management assistance to clients, focusing on various modification packages, market analysis, and catalog/pricing updates.


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