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Breakout Session # Presented by FedLinx’s Mrs. Linda Rodden, Director, GSA Compliance Dr. Tomi Bryan, President & PowerPoint Presentation
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Breakout Session # Presented by FedLinx’s Mrs. Linda Rodden, Director, GSA Compliance Dr. Tomi Bryan, President & - PowerPoint PPT Presentation


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Preparing for a GSA Audit: Creating Positive Outcomes. Breakout Session # Presented by FedLinx’s Mrs. Linda Rodden, Director, GSA Compliance Dr. Tomi Bryan, President & General Counsel Date April 16, 2008 Time 9:40 a.m. to 10:40 a.m. 2108. Why You Will Be Glad You Came!.

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Preparing for a GSA Audit: Creating Positive Outcomes

Breakout Session #

Presented by FedLinx’s

Mrs. Linda Rodden, Director, GSA Compliance

Dr. Tomi Bryan, President & General Counsel

Date April 16, 2008

Time 9:40 a.m. to 10:40 a.m.

2108

why you will be glad you came
Why You Will Be Glad You Came!
  • This program examines the following:
    • Ways to prepare for Contractor Assist Visits (CAV)
    • Methods for cross-checking the accuracy of reported sales and IFF payments
    • Understanding how to organize contract information to meet the needs of the Industrial Operations Analyst (IOA) conducting the visit
  • Goal: to achieve a positive outcome for your company
types of gsa audits
Types of GSA Audits
  • CAV
    • Visit to your company by an IOA
    • Follows the Contractor Assessment Initiative Report Card (Report Card)
    • GSA does not consider this an audit
    • If GSA is looking at your company records, it’s an audit
    • Findings are made by the IOA and submitted to your company’s GSA CO
types of gsa audits5
Types of GSA Audits
  • CAV continued
    • If your company disagrees with the findings on the Report Card, you can provide additional information to the CO in support of your company’s claims
  • Pre-award audit
    • Conducted by the Office of Inspector General (OIG)
    • Usually focuses on sales data (about 12 months worth)
types of gsa audits6
Types of GSA Audits
  • Pre-award audit continued
    • Auditors are looking to determine whether GSA is receiving best price and whether the MFC is the tracking customer
  • Post-award audit (Whistle-blower, just your company’s turn)
    • Conducted by the OIG
types of gsa audits7
Types of GSA Audits
  • Post-award audit continued
    • Conducted by the OIG
    • Auditors comb through all types of data
    • Mission is to uncover non-compliance
preparing for any audit
Preparing for any Audit
  • Request for Data
  • Entrance Conference
  • Space and Equipment
  • Contact Person
  • Handling records requests
  • Conclusion
preparing for a cav
Preparing for a CAV
  • Preparing for a CAV starts long before you receive notice of a visit:
    • Your company should have already reviewed the requirements in the Contractor Assessment Initiative Report Card (Report Card)
    • The Report Card can be found at this link: http://vsc.gsa.gov/casi/New_Casi.pdf
preparing for a cav10
Preparing for a CAV
  • The items identified in Category 1of the Report Card are deemed critical
  • Failure to meet any one (1) of these ten items will result in a rating of serious concerns exist:
    • Scope
    • Trade Agreements Act Compliance (TAA)
preparing for a cav11
Preparing for a CAV
  • Failure to meet any one (1) of these ten items will result in a rating of serious concerns exist:
    • Pricelist being used is current & approved
    • System in place that identifies, tracks and reports GSA sales accurately & completely
      • Dealer sales are included in 72A report
    • Meeting sales requirement (not discussed)
preparing for a cav12
Preparing for a CAV
  • Failure to meet any one (1) of these ten items will result in a rating of serious concerns exist:
    • System in place to monitor basis of award (BOA) customer
    • Pricing accuracy: Approved GSA price or lower being charged
    • Compliance with EPA clause
preparing for a cav13
Preparing for a CAV
  • Failure to meet any one (1) of these ten items will result in a rating of serious concerns exist:
    • Subcontracting plan goals met/progress toward meeting them (not discussed)
    • Accurately identifying products that have environmental attributes
scope
SCOPE
  • MEANING: Company sells products/services within scope of contract
  • METHOD:
    • Identify items as on contract versus open market
    • Have an open market section on quotes, customer acknowledgement and invoice
    • Program software to identify each line item as open market or on contract

Must start this process long before the CAV is scheduled

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TAA
  • MEANING: Products/services on Schedule must be designated country end product (See FAR 52.225-5)
  • METHOD:
    • Obtain COO information from manufacturer through LOS
    • Process for updating LOS information at least annually regular intervals
current approved pricelist
CURRENT, APPROVED PRICELIST
  • MEANING: Contractor is quoting to agencies using the latest GSA published pricelist
  • METHOD:
    • Process for updating and distributing the GSA published pricelist internally
    • Spot check invoices to confirm price charged to customer is what has been approved by GSA
iff system
IFF SYSTEM
  • MEANING: Contractor has a system in place that substantially identifies, tracks and reports GSA sales accurately and completely
  • METHOD:
    • Must be able to associate product/service sold with a specific SIN (identify SIN on order by product manually or electronically through order or accounting software)
iff system18
IFF SYSTEM
  • METHOD continued:
    • Must be able to track each time that product/service is sold to a GSA Customer (as simple as identifying the order as a GSA order versus open market order)
    • Must be able to determine total amount sold by SIN on a quarterly basis (can calculate manually or electronically in ordering/accounting software)
boa monitoring
BOA MONITORING
  • MEANING: Contractor has a system in place to monitor the "basis of award" customer discount relationship (purpose here is to avoid triggering price reductions clause (PRC)
  • METHOD:
    • Determine who the BOA customer is for your contract
boa monitoring20
BOA MONITORING
  • METHOD continued:
    • Determine the pricing relationship between the BOA customer and GSA
    • Check quotes to the BOA customer before submission to ensure price relationship is maintained (while a quote does not trigger the PRC, this is a great check point)
    • Check orders/awards from the BOA customer before acceptance to ensure price relationship is maintained
pricing accuracy
PRICING ACCURACY
  • MEANING: Contractor charges customers the contract price or lower
  • METHOD:
    • Hard code price into order entry/accounting software
    • Use only latest GSA Published pricelist if manual quote/order creation
    • Spot check invoices to confirm price charged to GSA customer is what has been approved by GSA
slide22
EPA
  • MEANING: Contractor is complying with the EPA clause of the contract
  • METHOD:
    • Read the contract to determine what the EPA requirements are
    • Every time prices change, modify the contract
    • Have a GSA pricing team that reviews price at least annually to determine if an EPA is required
environmental attributes
ENVIRONMENTAL ATTRIBUTES
  • MEANING: Contractor accurately identifying products that have environmental attributes
  • METHOD:
    • Obtain environmental information from manufacturer through LOS
    • Process for updating LOS information at least annually
federal procurement data system
Federal Procurement Data System
  • Many IOA now pull data from FPDS for a CAV – www.fpds.gov
  • FPDS data has GSA orders listed and CAV will ask you to pull a specified number of orders
    • IOA is looking for a lifecycle of paperwork that shows company is identifying, tracking and remitting correct IFF amount
    • This paperwork should also identify items that are open market
federal procurement data system25
Federal Procurement Data System
  • Conduct a self audit now!!!
  • Pull FPDS data and act like an IOA
    • Look for a lifecycle of paperwork that shows company is identifying, tracking and remitting correct IFF amount
    • Make sure this paperwork also identifies items that are open market
  • If your self-audit reveals misalignment with industry best practices, implement new measures that create realignment
organizing contract information
Organizing Contract Information
  • Keep data organized
  • We suggest maintaining Documentation Libraries – paper or electronic
  • Basic Libraries include: contract award, contract modification, commercial pricelists, GSA published pricelists, GSA quotes, GSA orders, BOA orders and open market orders, IFF
questions
QUESTIONS
  • Dr. Tomi Bryan:

tbryan@fedlinx.com or 336.379.0442

  • Ms. Linda Rodden: lrodden@fedlinx.com or 336.379.0442