GSA Makes Rare TAA Exception for COVID-19

Learn about the unusual GSA exception to the TAA during the COVID-19 pandemic, as well as key updates and highlights, and products allowed under the temporary exception.

GSA Makes Rare TAA Exception for COVID-19

As part of a momentous endeavor to mitigate the ongoing COVID-19 pandemic, the General Services Administration (GSA) took an exceptional step. This involved bending the stringent compliance requirements of the Trade Agreement Act (TAA) for specified goods listed on the GSA Schedule. Under traditional circumstances, these products are expected to live up to the TAA criteria, primarily implying they are manufactured or fundamentally changed within the United States or a TAA-designated nation. Yet, in these unprecedented times of increased global demand for critical supply items, the GSA officially recognized that trade agreement compliant sources were scarce.

The Evolution of GSA's TAA Exception

Briefly touching the past, we identify a few significant dates attached to this change:

  • April 29, 2021: The non-TAA exception, seemingly unneeded, was due to conclude on April 30, 2021. In preparation, GSA proposed to issue a one-sided contract adjustment to clear the non-TAA compliant products temporarily awarded from MAS contracts, simultaneously ensuring their withdrawal from GSA Advantage.

  • The TAA exception was extended until September 30, 2021.

  • It was further extended until March 31, 2021.

  • Previously, it saw an extension up to December 31, 2020, when disposable gloves joined the list of permissible products.

Dissecting the TAA Exception Memo

The GSA’s TAA Exception Memo firmly stated that:

  • The exception was confined to non-TAA compliant products that could be procured only for orders supporting COVID-19 response initiatives of the government.

  • Products originating from nations recorded in FAR 25.7 (Cuba, Iran, Sudan, Burma, North Korea) weren't eligible for coverage under this exception.

  • Conditions necessitated that non-TAA compliant products be distinctly identified when responding to RFQs.

  • Originally in effect until July 1, 2020, the duration was extended to December 31, 2020, and beyond as deemed necessary.

  • Businesses were allowed to supplement non-TAA compliant products to current GSA Schedule Contracts. However, new GSA Schedules for non-TAA compliant products wasn't permitted.

The Approved Product List under Temporary TAA Exception

In specific Federal Supply Classes (FSCs), the exceptions made provisions for some non-TAA items:

  1. FSC 4240: N95 masks

  2. FSC 6810: Sodium Hypochlorite (bleach)

  3. FSC 6840: Disinfectants, including cleaners, sprays, and wipes

  4. FSC 7930: Cleaners, including sanitizing surface and floor cleaners

  5. FSC 8415: Disposable Gloves

  6. FSC 8520: Hand Sanitizers, soaps, and dispensers

Final Thoughts

This provisional deviation by the GSA marked a unique but indispensable step towards adequate resource availability for governmental COVID-19 response measures. It throws light on the GSA's flexibility and promptness in crises, echoing their commitment to meet the pressing needs of the public and government. With services directed by a former GSA Schedule Reviewer, we take pride in providing top-notch GSA Schedule Consulting services.

In essence, the language that reaches the audience must be simple, accessible, and void of complex terms. It's this clarity that achieves readability and, in turn, the objective of effective communication. So, endeavour to let your words make an impact!

Pedro has extensive background as a Contracting Officer and Contract Specialist, has worked across seven federal agencies, managing contracts totaling over $1 billion in the professional and tech sectors. His notable tenure includes serving with the DoD/DARPA during the inception of their robotics program. Additionally, he played a pivotal role in initiating the Cyber Special Item Number (SIN) within the GSA's IT Schedule 70 as a Team Lead. After graduating from Harvard, he started Blackfyre to help you win your next contract.

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