Title : 4 Key Changes to GSA | What You Need to Know

The General Services Administration (GSA) has announced that they will be implementing Refresh 4 of the Multiple Award Schedule (MAS) Solicitation on August 13, 2020. This critical update will bring about substantial changes to the GSA MAS Contract. As a result, every contractor will receive a mass modification to integrate these changes into their existing contracts. Keep reading to get a quick overview of the major changes.

Key Changes In Refresh 4:

1. Prohibited Telecommunications:

The most noteworthy change comes under Part B of Section 889. This amendment extends the certification requirement beyond the confines of government contracts. Contractors are now obligated to guarantee that they do not use prohibited telecom equipment, spanning all their business operations, and not just government contracts.

• Background: This comes after a previous mass modification (Part A), where the focus was on banning the use of forbidden telecom equipment, particularly in government contracts.
• Resources: The GSA has provided an overview and a Frequently Asked Questions (FAQ) document for Section 889 Part B. All contractors should review this to ensure they are compliant.

2. Past Performance Requirements:

The process has undergone a change here. It is now the responsibility of contractors to acquire and submit Past Performance Questionnaires (PPQ) from references. Earlier, GSA used to handle this by reaching out to references directly. The aim of this switch is to fast track the proposal review process.

• Impact: This modification could possibly lead to reduced review times and fewer proposal rejections stemming from unresponsive references.

3. Deletion of Two Special Item Numbers (SINs):

The GSA MAS Contract will no longer offer Used/refurbished IT equipment (SIN 33411REF) and rental of IT equipment (SIN 132-4/532420R).

• Reasoning: The GSA has pointed to supply chain vulnerabilities as the primary cause for this change.

4. AbilityOne Products:

There's been a clarification in this area. Products that are "Essentially the Same" as those sold through the AbilityOne Program cannot be offered under the GSA MAS Contract, and this holds true even for AbilityOne Distributors.

A Note on the Removal of Clause 52.222-17:

The clause which mandated that service contractors had to offer right of first refusal of employment to employees of the previous contractor has been stricken off. It is expected that this could have an impact on employment practices under new contracts.

Contractors, Here's Your Action Plan:

1. Quick Acceptance: Contractors need to accept the Refresh 4 mass modification without delay as it takes effect on August 13, 2020. Swift acceptance is vital for continuing to receive orders under the GSA MAS Contract.
2. Deep Dive into Section 889: It is advisable to review and understand the requirements of Section 889 Part B thoroughly to ensure compliance.
3. Proactive PPQs: Contractors should be proactive and engage actively with their references to secure completed PPQs for proposal submissions.
4. Adjustment to SIN Deletions: Contractors who are currently offering products under the deleted SINs should re-evaluate their offerings and strategies.

Authentication Process for Mass Mods:

The authentication process has been revamped too. A new Multi-Factor Authentication (MFA) process has replaced the old method which required a digital certificate or a PIN for signing mass mods. However, contractors are required to have digital certificates for modifications through the eMod system.

Instructions on the MFA process are available on GSA Interact, and all contractors are encouraged to familiarize themselves with it.

Blackfyre's Support:

Blackfyre is a leading GSA schedule consultant and we are here to support you through these changes. We offer guidance on compliance, proposal support, and contract modification assistance. Need tailored support? Reach out to Blackfyre today or subscribe to stay informed on GSA updates.

Remember to stay compliant, proactive, and adaptable! Happy contracting!