GSA Schedule Contracts
Schedules, also known as Federal Supply Schedules or Multiple Award Schedules (MAS), are long-term governmentwide contracts that the U.S. General Services Administration (GSA) has with commercial companies, to provide access to millions of commercial products and services at fair and reasonable prices to the government. Schedules make buying easy and efficient with the use of modern technology to connect government buyers and industry. Schedule policy and procedures are guided by two major governing regulatory documents:
- Pursuant to 41 U.S.C. 152(3), FAR Part 38 prescribes policies and procedures that GSA must follow in managing the Schedules program.
- FAR Subpart 8.4 prescribes ordering procedures for federal agencies when placing orders for supplies and services under Schedules.
- General Services Administration Acquisition Manual (GSAM) –GSAM covers GSA acquisition policies and practices.
Directed and managed by the GSA, the FSS or Multiple Award Schedule (MAS) Program is designed to provide discount resources to all GSA federal agencies worldwide, as well as state and local governments. Under this program, a contractor can sell to any government agency with just one source, instead of having separate contracts with each agency. Per FAR 8.402, the Program consists of numerous indefinite delivery contracts to provide supplies and services at stated prices for a given period of time. Agencies obtain goods and services by placing orders with a schedule contractor utilizing the procedures set forth in FAR Subpart 8.4. Agencies can also use Blanket Purchase Agreements as the vehicle for acquiring goods/services from a specific schedule. Under FAR 8.405-3, A GSA Schedule BPA is an agreement established by a government buyer with a Schedule contractor to fill repetitive needs for supplies or services. BPAs make it easier for the contractor and buyer to fill recurring needs with the customer’s specific requirements in mind, while using the buyer’s full buying power by taking advantage of quantity discounts, saving administrative time, and reducing paperwork. Importantly, so long as the Federal Supply Schedules utilized the procedures provided at FAR Subpart 8.4, orders placed under those schedules are considered to be issued using full and open competition and therefore in compliance with the Competition in Contracting Act.
As of April 2020, the GSA is in the process of consolidating the 24 existing schedules in one master schedule, known as the Multiple Award Schedule (MAS). The MAS will be broken into 12 large categories including Facilities; Furniture & Furnishing; Human Capital; Industrial Products & Services; Information Technology; Miscellaneous; Office Management; Professional Services; Scientific Management and Solutions; Security and Protection; Transportation and Logistics; and Travel.
Best Procurement Approach Determination
FAR 17.500 prescribes policies and procedures applicable to all interagency acquisitions and specifically addresses in part ordering under GSA Schedules contracts. IAW FAR 17.502- 1(a)(2), prior to placing an order with a value greater than $500,000, the agency shall make a determination that use of GSA Schedule contracts constitutes the best procurement approach that fulfills the ordering activity’s needs. This determination, at a minimum, must include an analysis using the following factors:
- The suitability of GSA Schedule as the contract vehicle
- The value of using the contract vehicle, including:
- The administrative cost savings from using an already existing contract
- Lower prices, greater number of vendors, and reasonable vehicle access fees
- The expertise of the requesting agency to place orders and administer them against the selected contract vehicle throughout the acquisition life cycle. In short, this determination shows that the use of the GSA Schedule contract is the most advantageous method of acquisition for the ordering activity.
Small Business Participation
Under the GSA’s Small Business Administration (SBA) policy, agencies are allowed to include in their procurement base and goals, the dollar value of orders expected to be placed against Schedule contracts, and to report actual Schedule procurements as accomplishments against these goals. Currently, orders to Schedule 8(a) contractors do not receive 8(a) credit. However, since 8(a) contractors are, by definition, small disadvantaged businesses, ordering activities may count awards to such companies against their small business goals. “Set-asides,” as described in FAR 8.405-5, are now allowed under the GSA Schedules program at the discretion of the ordering activity’s Contracting Officer. Ordering activities may also consider socioeconomic status when identifying contractor(s) for consideration or competition for award of an order or Blanket Purchase Agreement. At a minimum, ordering activities should consider, if available, at least one small business, veteran-owned small business, service-disabled veteran-owned small business, HUBZone small business, women-owned small business, economically disadvantaged women-owned small business, or small disadvantaged business Schedule contractor(s).