A Talk With Shauna Weatherly: Navigating GSA Schedule Changes in 2024

Jun 5, 2024

The GSA Schedule, a cornerstone of federal procurement, is undergoing significant changes in 2024. To help businesses and contractors navigate these updates, we sat down with Shauna Weatherly, an expert in government contracting and a federal acquisition subject matter expert with over three decades of experience in the federal service.

In this interview, we cover the most critical developments, including new platforms, data reporting changes, joint venture requirements, and more. Whether you are an existing GSA schedule holder or new to it, Shauna’s insights will provide valuable insights into what lies ahead.

Shauna, thank you for agreeing to speak with us on this important theme. To begin with, what do you think are the most significant updates to the GSA MAS Schedule this year?

Shauna: This is probably one of the most active years in the GSA Federal Acquisition Service (FAS) and the GSA Multiple Award Schedules (MAS) since Schedules consolidation.

In terms of the Schedules themselves, there are several things the MAS Program Office is juggling right now.

Refresh 20 and 21

  • Refresh 20 was issued on April 15, 2024. Price Proposal Templates (PPTs) were updated for Products eOffers and eMods as well as Services and Training eOffers.
  • Refresh 21 is targeted for release in May 2024 (yet to be issued as of the date of this blog). There are two big changes in my opinion, outside of the changes to SINs. They are:
  1. For applicable contracts, adds four new optional Transactional Data Reporting (TDR) data elements: Order Date, Ship Date, Zip Code Shipped To, and Federal Customer – Treasury Agency Code. These fields will be available for reporting after 7pm ET on June 30, 2024.
  2. A note to FAR Clause 52.232-36, Payment by Third Party, that reads, “Credit card fees or convenience fees must be included in the approved MAS price, not added as a separate line item.” GSA Schedules require that vendors accept the Governmentwide Commercial Purchase Card (or GPC, or “P-Card”, for short) for all orders regardless of value, if required by the ordering agency.
  3. PPTs will not be updated in Refresh 21, except SIN 561510 Travel Agent Services.

Related to Joint Ventures (JVs) and requirements under GSA Schedules, Refresh 16 in May 2023, clarified how MAS offeror instructions applied to JVs. GSA implemented the same requirements for existing JV MAS contractors in Mass Modification (Standard Form (SF) 30)) under MAS Refresh 17 in July 2023. In both actions, GSA clarified, among other things, that:

  • JVs must be registered in SAM.gov as a separate entity with its own Unique Entity Identifier (UEI).
  • JV requirements are in addition to standard MAS solicitation and contract requirements. All small business JVs must have a written JV Agreement in place. JV requirements differ depending on the type of entity (i.e., small or one of the various socioeconomic categories). See the appropriate Title 13 Code of Federal Regulations reference for each socioeconomic category for detailed instructions on the contents of the JV Agreement.
  • The JV partner performing under an awarded labor category must be identified in the offer and in the JVs price list on GSA Advantage!.
  • Any JV partner can have their own MAS contract and be a JV partner on up to three JV MAS contracts with one or more of the same SINs. However, the JVs may not submit competing quotes for MAS orders and Blanket Purchase Agreements (BPAs).
  • Mentor-Protege JVs can submit a MAS offer if they were awarded a Federal contract more than two years before an offer submission but the JV no longer qualifies for an exemption from affiliation.
  • Existing JV contractors had to submit the additional documents required of JV offerors and an updated PPT that identified which JV partner projects the awarded products and services.
  • JVs are subject to GSA’s standard process for exercising contract options.

GSA continues to provide clarifications in the MAS solicitation instructions to offerors through Refresh and Mass Modifications, as the need arises. For example, Refresh 21 will provide clarification that the 12-month waiting period and additional documentation requirements apply to Joint Venture partners who held a previous Schedule contract that was canceled / allowed to expire due to low or no sales or non-compliance.

FAS Catalog Platform (FCP)

Speaking of MAS solicitation instructions, FAS is also piloting the FAS Catalog Platform (FCP) with its MAS services contractors in a phased rollout starting in July 2024 with most contractors migrated in 2025. The Services Plus File (SPF) is web-based and will replace the Services and Training and Language Services PPTs. Services contractors will use the SPF to manage their catalogs. There are automated features built into the SPF that don’t exist with current PPTs. For example, when pricing doesn’t fit an expected pattern (i.e., entered in the correct field or format), a warning file is created to draw the Contracting Officer’s attention without a hard rejection of the offer, such as would be the case presently when a contractor proposes pricing where the price offered to GSA is not the lowest or when proposing out-year pricing that is not tied to the economic price adjustment (EPA) rate. The SCP will also auto-publish your price list in GSA Advantage!, eLibrary, and eBuy. This means that the latest pricing on the contract will be reflected in those systems without any extra effort from you. And that’s a good thing!

GSA Regional Structure

Lastly, we have changes in the structure of FAS itself, shifting several business lines from a regional structure (i.e., 10 geographic regions plus the National Capital Region (NCR)) to one that focuses on the agencies they service and industry partners.

Small Business Size Standards Methodology

Outside of the GSA MAS Program there are also proposed changes from Small Business Administration (SBA) related to the methodology used to determined small business size standards and a new rule from the Department of Labor (DoL) related to the Salary Thresholds for Exemption of Executive, Administrative, Professional, Computer, and Outside Sales Employees under the Fair Labor Standards Act. These also impact Federal contractors, including GSA Schedule holders.

Thanks, that was insightful. Speaking in general, how can schedule holders make the most out of their contract as the GSA Schedule evolves and transforms? What do they need to be prepared for in the future, in your opinion?

Shauna: Maintaining a business structure that allows you to meet ever-evolving and more complex compliance requirements is important with GSA Schedules. Too many times, Schedule contractors are hyper-focused on the “win.” But you also must perform. And performance includes things like compliance and reporting, which will likely grow. Things like proposed cybersecurity requirements and greenhouse gas emissions reporting (both in the current rulemaking pipeline), as well as evolving labor requirements like those from the Department of Labor, are just a few examples of things we’ve seen proposed or changed in the last year that will greatly impact businesses. Since GSA Schedules run 20 years versus the typically maximum of five years, a lot can change and you’ll need to have a way to keep up and continually adapt.

I see the Transactional Data Reporting (TDR) pilot expanding to more SINs in the future (but hopefully stay optional) given Category Management initiatives and the recent Office of Management and Budget (OMB) Circular A-137, Strategic Management of Acquisition Data and Information. Prices-paid information will likely play a role in the holistic view of acquisition data as a governmentwide asset to be leveraged across agencies. This “Hi-Def Environment” (or HDE) is in its infancy but knowing what I do having been a part of several discussions related to the initiative, I see GSA Schedule data being used for resourcing decisions since there are so many agencies who order against Schedules and sometimes pay a wide range of prices, after discounts.

Finally, the eOffer and eMod processes are also ever-evolving. Keeping track of the changes, like forthcoming use of the FCP, will be important to getting your Schedule changed or renewed in out-years.

That makes sense. Another hot topic is what contractors should know about the GSA’s shifting regional structure. Do you have any specific thoughts on that?

Shauna: Change is hard for everyone, especially after becoming used to one structure and way of doing things. However, in this case, the customer should see very little change and actually receive better customer service. While some of my former peers say six months in that this realignment has not been without its pain points, in the long term, I think the new structure will have three distinct benefits:

  • GSA teams will focus more on supporting a single agency or group of agencies.
  • GSA will acquire breadth and depth of knowledge of the customer’s mission to better meet that agency’s needs over time, and,
  • Hopefully, the new structure will provide more growth opportunities to the GSA acquisition workforce itself by providing a broader view and experience in the various types of contracts needed to meet that agency’s mission.

Shifting from stovepipes and mini-kingdoms to a more customer-centric approach, however, always takes time to get right both for the customer and the internal agency itself. GSA has some challenges with such a large shift in its delivery model given its wide geographic reach and largely telework-based workforce. However, those challenges can be easily overcome with good communication from GSA leadership. GSA Administrator Robin Carnahan and Acting FAS Commissioner, Tom Howder, are great communicators and I feel confident with them at the helm, things will be just fine. I’ve been through this on some smaller levels at other agencies. It always ends up being a positive change when you place the focus where it belongs–on the customer and meeting their mission.

Thanks. Many of our readers are recently registered small businesses and are wondering if the GSA Schedule suits them. From your experience over the years, do you think the GSA Schedule is worth pursuing for new government contractors, or is it better for new entrants to focus on smaller, more direct opportunities to build past performance?

Shauna: Pursuing a GSA Schedule only makes sense when you’ve done your homework, and everything lines up as a good fit. I get small and medium businesses ask me all the time about helping them get their first GSA Schedule. If they haven’t done their homework, I send them away to do that first, then we talk.

Let’s talk about why you should NOT pursue a GSA Schedule because I find that a lot of the time these are the reasons businesses approach me in the first place.

  • You see posts and ads (or talk to a consultant) that all say you need a GSA schedule. You don’t need a GSA Schedule to be successful in the Federal marketplace.
  • FOMO (Fear of Missing Out). You don’t make other business decisions this way. Don’t do it for this.
  • You have no established agency contacts or relationships. It is not a “build it, and they will come” contract. It’s a marketing tool to use with your existing agency contacts to help them streamline their acquisition process. No existing contacts = no or low sales.
  • You don’t know what is purchased on MAS, which agencies are buying what you sell (and if they are buying), or potential competitors and their MAS pricing.
  • You haven’t read the solicitation or know what Category, SIN, ODC, OLM, PPT, TDR, FSS, FAR, or FCP mean.
  • You have limited administrative resources to complete compliance and reporting in a timely manner. Don’t get in over your head. Have the resources and compliance structure you need in place to manage a Schedule contract BEFORE you get it.

So, if those are the wrong reasons, what are some of the right reasons? Pursue a GSA Schedule after you:

  1. Who is buying, and what are they buying under the Schedule? (USASpending.gov)
  2. Who are your competitors under the Schedule? (GSA eLibrary)
  3. Learn the lingo and READ the MAS solicitation and attachments.
  • Take the GSA Readiness Assessment.
  • Review what it takes to submit an offer using the MAS eOffer checklist.
  • Start building relationships with agency personnel (i.e., Contracting Officers, Small Business Specialists, Project Managers, and End Users).

GSA recently changed the rules related to sales needed to keep your GSA contract active from $25,000 in the first two years of the Schedule contract to $100,000 within the first five years AND $150,000 each five-year period thereafter. So all you need is one $100,000 order in the first five years, right? Considering that only around 40% of MAS contracts have any sales (60% have no sales), its not an automatic that you will hit the required sales threshold easily. If you are already in year two or three of a Schedule contract, have no sales, and have no existing Federal clients, you are already WAY behind the power curve. If your business doesn’t meet the sales thresholds, GSA may cancel your contract or allow it to expire.

I suggest small businesses have a multi-tiered approach to capture projects within the micropurchase threshold (MPT) (i.e., at and below $10,000), the simplified acquisition threshold (SAT) (i.e., over $10,000 and at or below $250,000), and over the SAT and ideally an Indefinite-Delivery Indefinite-Quantity (IDIQ) contract. Micropurchases are the closest thing to a handshake deal in Government contracts and are as simple as providing a quote to a buyer and accepting the Government Purchase Card (GPC). If you accept Visa or Mastercard you can accept the GPC. Simplified Acquisitions are set-aside for small businesses automatically unless otherwise justified. These two ranges are where small businesses can gain that experience.

Subcontracting opportunities are also a good way to learn and grow without the added responsibilities of being the prime contractor.

Thanks for the insightful answer. Final question – what would be your message for small businesses aspiring to get on the GSA Schedule this year?

Shauna: Once you decide a GSA Schedule is a good fit for your business, I suggest checking to see if your business qualifies for either of two avenues available to get a MAS Schedule a little more quickly than the traditional route.

One is the GSA Startup Springboard program that helps companies without the required two years of corporate experience to possibly substitute company executives and key professionals’ management and project experience for that of the company and provide documentation of financial responsibility when there are not two years of financial statements.

The other is for the Information Technology (IT) category only and is called FASt Lane. FASt Lane onboarding is just like it sounds, very fast. BUT there are eligibility requirements you must meet. The project must be associated with a FASt Lane-eligible initiative that has been identified by an agency to GSA, along with other additional documentation requirements. You must commit to respond to all Contracting Officer inquiries within 24 hours of receipt, or you will lose eligibility.

If you have to go the traditional route, be patient and understand that it can take time. Plan on four to six months at a minimum. This is why you want to do your homework so your eOffer package is correct and complete on your first submission.

Conclusion

The GSA Schedule is undergoing numerous updates in 2024, from new platforms and data reporting enhancements to policy shifts and joint venture requirements. Staying informed and proactive about these changes is crucial for contractors to remain compliant and competitive. Shauna’s insights underline how understanding and adapting to these developments, businesses can better navigate the federal procurement landscape and seize new opportunities.

Shauna Weatherly is a former federal acquisition expert with over 35 years of government service. A passionate small business advocate, she founded FedSubK, a SBA-certified Women-Owned Small Business dedicated to empowering small businesses with the knowledge they need to thrive in the federal contracting arena.

Do you have questions about the GSA MAS Schedule changes or need assistance navigating the application or modification process? iQuasar’s experienced consultants can provide comprehensive guidance and support throughout your journey. Contact us today to discuss your specific needs and learn how we can help you achieve your GSA MAS Schedule goals.

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