6 Steps To Keep Your MAS Contract Compliant After Award

By Global Services on June 9, 2022


You’ve just been awarded a General Services Administration (GSA) Multiple Award Schedule (MAS) contract. Congratulations! We know your team devoted a lot of time and resources to this feat. Right now, you may be feeling like your worries are behind you. Unfortunately, there’s more work to be done. Now that you’ve been awarded, you must abide by the Terms and Conditions (T&Cs) of your contract, maintain compliance with the solicitation, modify your offerings, periodically report your sales, and remit the Industrial Funding Fee (IFF). We know, it’s a lot. To ease you into these post-award activities, our team has outlined some helpful steps to guide you through successful MAS contract management:


Step 1: Know Your GSA Team


The first thing you’ll want to do is locate and develop working relationships with your GSA Points-of-Contact (POCs). It’s important to know the difference between these POCs and who to contact for a particular task. You have three (3) main POCs that will help you navigate your MAS contract from pre-award negotiations to 20-year contract compliance:


Procurement Contracting Officer (PCO) – Your PCO or Contracting officer/Contracting Specialist, as you may remember, was the person who awarded your contract. Your PCO is your main go-to for day-to-day issues like adding new Labor Categories (LCATs) to your Schedule offerings or clarifying the applicability of an invoice. Each PCO will have different approaches or preferences for how they conduct business, so it’s essential you know how to work with them.


If you’re not sure who your PCO is, visit your company’s eLibrary listing. There, you can locate your PCO’s name, email, and phone number under “Govt. Point of Contact.”


Administrative Contracting Officer (ACO) – The ACO is a touching point for compliance-oriented tasks like sales reporting and mass modifications (mods). ACOs are most active at the beginning of the contract award process, so it’s unlikely you’ll contact them on a regular basis. They are, however, the key POC for any general questions you may have like “Who is my Basis of Award (BOA)?” and “Where can I find copies of my award documents?”


Industrial Operations Analyst (IOA) – The IOA is the person who assesses your contract activities, conducts Contractor Assessment Visits (CAVs) and Industrial Funding Fee (IFF) reviews, and monitors overall compliance. You won’t work with your IOA as frequently as you do with your PCO. IOAs are very black and white when it comes to compliance. If you’ve been noncompliant in any way, they’ll help you understand why to avoid that pitfall moving forward. If you want to double check a spot discount to an ordering agency or if you need clarification on a particular solicitation clause, your IOA is a good resource.


You can find your ACO and IOA through the POC Locator on the Vendor Support Center (VSC). Type in your contract number and the search results will show your ACO and/or IOA’s name, email address, and phone number.


Step 2: Post Your Pricelist After Award


After award, you are required to create and upload your final GSA MAS Schedule pricelist to GSA sites like eLibrary and GSA Advantage! no more than 30 days from time of award. Your pricelist can only reflect items and T&Cs awarded to you. It’s your responsibility, not GSA’s, to keep your posted pricelist current and up to date.


Your pricelist is a perfect avenue to highlight your expertise and strengths to agency customers. Just keep in mind that there are rules for this document. The format of the pricelist is dictated by the MAS solicitation and your CO has final approval regarding the formatting, aesthetics (logos and graphics), and content. Make sure to check with your CO when drafting this pricelist to yield the best results.


Remember, information on an approved pricelist can only be altered through a MAS mod. Need to change a product name or service description? You’ll need to submit a mod. Looking to add a Special Item Number (SIN) to your breadth of offerings? You’ll need to submit a mod.


P.S. Make sure to keep all iterations of your pricelist on file. GSA can assess your MAS-related activities up to three (3) years after contract expiration/termination date. By keeping a library of all versions, you’re best protecting your interests in the event they return to investigate your prices or offerings during any particular time in your contract’s life.


Step 3: Familiarize Yourself With These Sites


GSA knows that access to free and unlimited resources is crucial for the success of a MAS contractor. Any information you need relating to the MAS program can be found on various GSA-run sites. We’ve listed the main players below:


Vendor Support Center (VSC) – The VSC is THE source for MAS contractors. VSC is an online resource, accessible 24/7, 365. From getting on Schedule to analyzing sales, VSC has it all. For additional support, the VSC Help Center can be reached Monday – Friday, 8:30 a.m. – 5:30 p.m. Eastern Time (ET) at 877-495-4849 or vendor.support@gsa.gov. Please note that the VSC team cannot help with contract-specific questions, those are best directed to your PCO, ACO, or IOA.


GSA eLibrary – eLibrary is the home for contract awards. Here you can find vendor information and GSA pricelists by Large Category/SIN. This information will be useful for market research purposes, or to locate potential teaming partners.


GSA Advantage! GSA Advantage! is an online purchasing service for government agencies to obtain commercial products and services. There are thousands of contractors and millions of products and services on the site to date. It’s not only ideal to offer your products/services on this site, but mandatory as a MAS Schedule contractor. Contractors must use Schedule Input Program (SIP) to upload their electronic catalog. If you don’t know where to start, VSC has training courses available.


eBuy – eBuy is an online Request for Quote (RFQ) system run by GSA. Designed to simplify the acquisition process for federal buyers, eBuy allows agencies to post RFQs, find contractors, and prepare Requests for Proposals (RFPs) in real time. These opportunities are specific to you as a Schedule holder as only those with MAS Schedules may participate in eBuy. Only when your pricelist is visible on GSA Advantage! will you have access to eBuy.


P.S. If you fail to report sales or accept a mass mod, GSA will remove your pricelist and you’ll no longer have access to eBuy. So, stay alert!


Step 4: Know The Eligible Users


It’s vital that you know who can and cannot order from your GSA MAS Schedule. Beware businesses who try to order from you without eligibility to purchase under your Schedule. In the event that you sell your Schedule goods and/or services to an unapproved buyer, you will face the consequences, not the ordering party. Vigilance is key!


Currently, the following entities are eligible to purchase from the Schedules:


  • Federal agencies (military and civilian),
  • mixed ownership government corporations,
  • District of Columbia,
  • certain non-profit organizations for the blind or severely handicap (those that produce an approved commodity or service),
  • state and local governments,
  • and authorized contractors (FAR 51).


For a detailed list, please see Eligibility to Use GSA Sources of Supply and Services.


Step 5: Know How and When to Report Schedule Sales After Award


Before we dive into sales reporting, it’s important to know what constitutes a GSA sale. Luckily, GSA has provided a quick list of indicators for MAS sales:

  • “Product or service is on your GSA contract, including items sold under the Order Level Materials (OLM) SIN.
  • GSA contract number is stated on the purchase order or task order.
  • Ordering information and terms like delivery are the same as your GSA contract.
  • Customer made contact with you through GSA Advantage or eBuy.
  • Customer pays with the governmentwide commercial purchase card.
  • Pricing is at or below the MAS price.
  • There is no indication of any other procurement vehicle being used.
  • Sales to private company with a Letter of Authorization using FAR 51.”

As a MAS contractor, it’s your responsibility to report your sales. How frequently you report depends on what type of MAS contractor you are. Are you a Legacy contractor or Transactional Data Reporting (TDR) contractor? If you’re not sure which category you fall under, we’ll walk you through the difference below:


Legacy contract holders: You’re considered a Legacy contract holder if you disclosed a Most Favored Customer (MFC), commercial sales practices, and the ceiling/floor rates for your items on Schedule. When you disclosed the lowest rate you sell an item or service to your MFC, you identified your “commercial floor.” Meaning, as you move forward, you cannot sell for less than that floor. You also agreed on a discount for GSA which identified your “ceiling rate.” For GSA customers, you can charge below this “ceiling rate,” but you cannot charge lower than your “commercial floor.” The discount relationship established at the time of award is what needs to be maintained. Any change in the commercial pricing or discount arrangements constitutes a price reduction. If you’re Legacy, be sure you’re well informed on your discount structure, which should be clearly stated in your Final Proposal Revision (FPR) letter.


For Legacy contractors, sales must be reported within 30 days of the quarter’s end (January 1-March 31, April 1-June 30, July 1-September 30, and October 1-December 31).


TDR: TDR was designed to provide real-time market intelligence for GSA and other ordering agencies to look at what items were sold for. The TDR program is optional and only applies for certain SINs. Unlike Legacy, TDR does not require disclosure of commercial sales practices and does not require a BOA.


TDR sales must be reported within 30 days following each month’s end (in an itemized report). For more information, look to the VSC for TDR reporting instructions.


General Sales Practices:


  • It’s your responsibility to maintain a consistent accounting system and practices for sales reporting.
  • GSA has identified the following points for which sales may be reported:
    • Receipt of order,
    • shipment or delivery, as applicable,
    • issuance of an invoice, or
    • payment.
  • All MAS contractors must report their sales through the Federal Acquisition Service (FAS) Sales Reporting Portal (SRP).
  • All Schedule sales must be reported in U.S. dollars, rounded to the nearest whole dollar.
  • Even if you’ve had no sales, you have to report $0 dollars.


Additionally, you are also to remit your 0.75% IFF based on your reported sales. Legacy contract holders will pay quarterly, while TDR contract holders may choose to pay monthly or quarterly. The IFF was most likely added to your finalized pricing of each product or service proposed. The IFF actually covers the operating costs of the Federal Supply Schedule (FSS). So, you can be sure GSA will follow up on any failure to remit the IFF!


Step 6: Know How to Accept and Submit for Mods


It’s your responsibility as a contractor to keep your MAS contract current and up to date. This is done through mods. Whether GSA needs you to accept new solicitation clauses or you need to add more services to your list of offerings, mods are your path forward.


There are two types of Schedule mods: Unilateral and Bilateral.


Unilateral mods, known as mass mods, come from GSA. These are mandatory for all contract holders and must be accepted within 90 days. These mods require you to accept solicitation changes (known as MAS Refreshes) that will be incorporated into your contract.


Bilateral mods, known as Schedule mods, are optional and initiated by the contractors. These are content updates for your Schedule such as adding LCATs or changing the authorized negotiator on file. Any mod your business submits must be approved by your PCO. Some of the more notable mods are:


  • technical,
  • administrative,
  • additions,
  • deletions,
  • pricing,
  • legal,
  • T&C changes,
  • options/extensions,
  • and cancellation or termination.


If you’re interested in updating your Schedule offerings, but don’t know where to start, download the MAS Modification Guidance here. Please note that pre-award submission instructions/templates differ from those of Schedule mods. Always check GSA’s MAS Roadmap site to collect the most current versions.


We hope you enjoyed this brief overview of post-award steps you and your business must take to maintain your MAS Schedule. For more insight, join us for our GSA Schedule Post-Award Compliance Training series!



In our 20+ years of business, Global Services has a 100% win rate for MAS Schedule contracts. If you need assistance with MAS modifications, reach out to our experts today!