A GSA Compliance Checklist is a structured guide used by contractors and internal compliance teams to ensure adherence to the rules, regulations, and reporting obligations associated with holding a GSA Multiple Award Schedule (MAS) contract. This checklist helps vendors stay compliant throughout the contract lifecycle—from award to contract management, modifications, and closeout.
Compliance with GSA contract terms is not optional. It is a critical part of maintaining good standing with the General Services Administration and avoiding penalties, audit findings, contract suspension, or termination. The checklist acts as both a risk management tool and a roadmap for operational integrity.
Purpose and Importance
The federal acquisition system is governed by a complex set of policies, including the Federal Acquisition Regulation (FAR), GSA-specific clauses, and ongoing reporting and pricing requirements. For contractors, understanding and managing these obligations is essential not only for legal and regulatory compliance, but also for long-term business success in the public sector.
Using a compliance checklist helps contractors:
- Monitor and track recurring obligations such as sales reporting, price updates, and order processing
- Prepare for audits and Contractor Assessment Visits (CAVs) conducted by the Industrial Operations Analyst (IOA)
- Reduce risk of mispricing, invoicing errors, or noncompliance with trade laws such as the Trade Agreements Act (TAA)
- Maintain eligibility for future GSA opportunities, contract modifications, and renewals
- Improve internal communication between contract, finance, and sales teams
A well-maintained checklist ensures that no requirement is overlooked—especially those that are time-sensitive or contract-specific.
Core Compliance Areas
The GSA MAS contract includes dozens of clauses and administrative requirements, many of which apply throughout the life of the contract. Contractors are expected to implement internal controls, document processes, and maintain accurate records to demonstrate compliance.
A typical GSA compliance checklist includes the following obligations:
- Maintain an active SAM.gov registration with current points of contact and representations and certifications
- Ensure that all listed products and services on GSA Advantage! match the most recent approved pricing and descriptions
- Verify Trade Agreements Act (TAA) compliance for all offered products, with clear Country of Origin information
- Submit Industrial Funding Fee (IFF) payments and quarterly sales reports via the FAS Sales Reporting Portal on time
- Track and honor the Price Reductions Clause (PRC) if applicable, ensuring that GSA receives the same or better pricing as the Most Favored Customer (MFC)
- Maintain required labor category descriptions and qualifications for service-based SINs
- Update catalog and pricing information using SIP or FCP after approved modifications
- Participate in IOA assessments and provide requested documentation, including invoices, price lists, and commercial sales practices
- Comply with cybersecurity requirements, such as NIST 800-171 for contractors handling sensitive information
- Display required contract information in online listings and on order confirmations, including contract number, SINs, and delivery terms
Each of these items may require supporting documentation, system access, or cross-functional coordination to manage properly.
Best Practices for Staying Compliant
Compliance is not a one-time event—it is an ongoing effort that requires vigilance, communication, and structure. Many successful GSA contractors build compliance into their daily workflows and assign ownership across departments to ensure accountability.
Recommended practices for managing GSA compliance effectively include:
- Designate a compliance lead or internal GSA contract administrator to own the checklist and coordinate tasks
- Create a shared compliance calendar with recurring reminders for reporting deadlines, updates, and training
- Document all contract actions, including modifications, communications with GSA, and justification for pricing decisions
- Conduct internal spot checks or mock IOA reviews quarterly or semi-annually
- Use GSA-provided tools such as the Vendor Support Center, eMod, eBuy, and GSA Interact to stay informed and current
Additionally, some contractors implement contract management software or hire compliance consultants to manage more complex portfolios.
Conclusion
A GSA Compliance Checklist is an essential tool for managing risk and ensuring consistent, proactive adherence to the many requirements of a GSA Schedule contract. It helps contractors stay organized, respond confidently to audits, and maintain strong performance throughout the life of the agreement. As GSA continues to modernize and increase oversight, a well-structured checklist is more important than ever for vendors who want to thrive in the federal marketplace.
