Breakout Session

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Preparing for a GSA Audit Creating Positive
Outcomes
Breakout Session Presented by FedLinxs Mrs.
Linda Rodden, Director, GSA Compliance Dr. Tomi
Bryan, President General Counsel Date
April 16, 2008 Time 940 a.m. to 1040 a.m.
2108
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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

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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, its
  an audit
• Findings are made by the IOA and submitted to
  your companys GSA CO

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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
  companys claims
• Pre-award audit
• Conducted by the Office of Inspector General
  (OIG)
• Usually focuses on sales data (about 12 months
  worth)

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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
  companys turn)
• Conducted by the OIG

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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

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Preparing for any Audit

• Request for Data
• Entrance Conference
• Space and Equipment
• Contact Person
• Handling records requests
• Conclusion

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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

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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)

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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)

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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

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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

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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

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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

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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)

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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)

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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

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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

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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

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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

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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

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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

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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

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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

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QUESTIONS

• Dr. Tomi Bryan
• tbryan_at_fedlinx.com or 336.379.0442
• Ms. Linda Rodden lrodden_at_fedlinx.com or
  336.379.0442