GSA Schedule & VA Contract Compliance & Investigation Services
Our experts provide clients with practical solutions, with a focus on effective business operations and regulatory compliance.
Navigating systems and compliance requirements of government contracting.
For many companies, the systems and compliance requirements of government contracting are barriers for entry into and expansion within the government marketplace. US General Services Administration (GSA) Schedule contracts and Department of Veteran’s Affairs (VA) Schedule contracts, as commercial item acquisitions with streamlined requirements, are often the preferred contract vehicles used by companies to overcome the barriers of unique government requirements to penetrate and grow within the government market. However, these vehicles carry their own unique pricing and compliance risks, which can result in significant financial and reputational losses when not managed effectively.
GSA and VA Schedule contract audits are performed by the agencies’ respective Office of Inspector General (OIG). BRG professionals have extensive experience working with companies undergoing OIG audits by helping identify and resolve typical audit issues, providing support during actual audits, and advising in the negotiation of audit findings. In addition, we advise clients on more routine Contractor Assistance Visits performed by GSA Industrial Operations Analysts.
BRG offers extensive and unique industry experience with respect to a variety of GSA and VA Schedule matters, including:
- Strategic price analysis and Commercial Sales Practices disclosures
- Competitor price analysis
- Preparation of Contract Renewal Support
- Negotiation of basis of award customer and pricing relationships
- Price Reduction Clause monitoring and reporting
- Compliance with sales reporting and Industrial Funding Fee payment requirements
- Advising clients and counsel by providing independent reports and damages analysis as part of investigations of allegations of violations of the False Claims Act
- OIG audits
- Internal audits, investigations and voluntary disclosures
GSA and VA Schedule Audits and Investigations
We advised a computer software company in undergoing an extensive OIG investigation regarding pricing and discounting practices over an extended time frame, which incorporated multiple Schedule renewals. We advised in analyzing pricing and discounting practices on hundreds of millions of lines of commercial and government transactions in an effort to negotiate a reasonable settlement with the GSA.
We advised a client with various GSA Schedule compliance matters, including evaluating contract compliance, evaluating and maintaining commercial and GSA Schedule price lists, and developing processes and controls to administer contract requirements and monitor for alleged noncompliant activities.
We advised a large GSA Schedule contractor in an OIG investigation related to the sale of “open market” items under its Schedule contract. We advised in assessing the company’s practices relative to open-market pricing and billing issues. We worked with legal counsel to develop corrective actions for the company to implement. We also advised in negotiating a settlement by the company with the agency.
Assistance in Obtaining and Pricing GSA and VA Schedule Contracts
We have helped companies successfully obtain initial GSA Schedule contracts. Our services range from strategic pricing analysis and identification of pricing and negotiation strategies to ultimate preparation of Commercial Sales Practices (CSP-1) disclosures. Using data analytics, we provide clients with meaningful analysis of actual sales data to enable negotiation of fair and reasonable pricing, while at the same time mitigating the compliance risks associated with defective pricing and other unique pricing requirements like the Price Reduction Clause.
Assistance in Establishing Controls and Systems for GSA and VA Schedule Compliance
Our experts advise clients in establishing the internal control, contract administration, accounting, and sales reporting systems necessitated by the compliance requirements of GSA and VA Schedules.
We advise organizations by reviewing internal processes and controls, including systems to monitor and report price reductions or evaluating processes to accurately identify and report sales under the contract and calculate and remit the appropriate Industrial Funding Fee (IFF). In addition we provide recommended strategies for strengthening Schedule contract compliance. Finally, we advise clients with implementing recommendations and providing appropriate training to key stakeholders within the organization as it relates to Schedule contract administration and compliance.
Assistance With GSA and VA Schedule Contract Renewals
Most Schedule contract audit and investigation issues arise during the contract renewal process. Our experts have advised clients in the successful renewal of GSA Schedule contracts, including reviewing and updating CSP disclosures and enhancing pricing strategies for offered products and services. We have also advised companies with preparing for audits of GSA Schedule contract renewals and have supported companies through successful audits.
We routinely prepare and facilitate training on GSA Schedule matters for contractor personnel, including staff within the contract administration, compliance, internal audit, pricing, and sales and marketing functions.