GSA Schedule Compliance refers to a contractor’s ongoing adherence to all terms, conditions, and regulatory requirements of the Multiple Award Schedule (MAS) program. This includes meeting contractual obligations related to pricing, reporting, administrative updates, modifications, minimum sales thresholds, and performance standards.
Compliance is not a one-time requirement, but a continuous responsibility throughout the life of the contract. Contractors that maintain strong GSA compliance avoid audit risk, retain good standing, and increase their likelihood of contract renewals and future awards.
Key Areas of GSA Schedule Compliance
Contractors must consistently manage several core areas to remain compliant under the MAS program. These areas include:
1. Minimum Sales Threshold
Contractors must meet the minimum sales requirement of $100,000 during the initial 5-year base period. Failure to meet this threshold may result in contract cancellation. Contractors should:
- Track quarterly sales
- Identify underperforming SINs or categories
- Engage in targeted marketing to federal buyers
2. Timely Sales Reporting
Quarterly sales must be reported through the FAS Sales Reporting Portal (SRP) by the deadlines defined in the contract. Reporting must:
- Include all sales made under the GSA Schedule
- Be accurate and match internal invoicing
- Be submitted on time to avoid penalties or flags
Contractors must also remit the Industrial Funding Fee (IFF) based on reported sales.
3. Accurate and Timely Modifications
Contractors are responsible for submitting contract modifications when:
- Adding or deleting products or services
- Updating pricing
- Changing company contact information or business size
- Adding or removing SINs
- Accepting Solicitation Refreshes via Mass Mod
Failure to maintain an up-to-date contract via eMod can result in out-of-compliance sales, buyer confusion, or audit findings.
4. Current and Compliant Catalog Listings
Product and service information must be accurate on platforms such as:
- GSA Advantage!
- GSA eLibrary
- FAS Catalog Platform (FCP)
All listed items must be awarded under the MAS contract and priced according to the approved contract terms. Inaccurate or expired listings may lead to a suspension of visibility or enforcement actions.
5. Prompt Contact Information Updates
Contractors must keep the following information current:
- Authorized negotiators
- Contract administrator contact
- Business address and legal name
- Email addresses and phone numbers in SAM.gov, eMod, and GSA systems
Outdated contacts may delay modification approvals, Mass Mod acceptance, or communication from the Contracting Officer.
6. Compliance with Terms and Clauses
Contractors must comply with all applicable FAR, GSAR, and contract-specific clauses. This includes:
- Trade Agreements Act (TAA) compliance
- Buy American Act, when applicable
- Price reductions clause, if included
- Labor laws for services under the Service Contract Labor Standards (SCLS)
- Socioeconomic and sustainability clauses if the contractor participates in those programs
Failure to follow these clauses can lead to audits, cancellation, or suspension from the program.
Oversight and Audits
GSA enforces compliance through periodic evaluations, including:
- Contractor Assessment Visits (CAVs) conducted by Industrial Operations Analysts (IOAs)
- Office of Inspector General (OIG) audits for high-risk or high-dollar contracts
- Performance reviews prior to option period extensions
- Data monitoring through SRP, FPDS, and GSA systems
Contractors must maintain records and be ready to demonstrate compliance in all areas at any time.
Consequences of Non-Compliance
Non-compliance with GSA Schedule obligations may result in:
- Rejected modifications
- Catalog suspension from GSA Advantage
- Missed sales due to outdated pricing or expired SINs
- Increased audit scrutiny
- Denied contract renewals or early termination
- Removal from the MAS program
Even isolated failures (e.g., missing a sales report or underreporting IFF) can lead to flags in your contract file and reduced buyer confidence.
Best Practices for Maintaining GSA Compliance
To stay compliant, contractors should:
- Assign a compliance lead or team responsible for GSA contract administration
- Conduct internal quarterly reviews aligned with SRP reporting cycles
- Keep a modification log with dates, statuses, and upcoming requirements
- Review Solicitation Refreshes and accept Mass Mods promptly
- Maintain alignment between SAM.gov, eMod, FCP, and your website
- Archive and back up all pricing approvals, catalogs, IFF payments, and communication with GSA
Using a compliance calendar and automation tools can help ensure nothing falls through the cracks.
Conclusion
GSA Schedule Compliance is fundamental to success in the federal marketplace. Contractors must proactively manage reporting, catalog accuracy, pricing integrity, and contract maintenance to stay in good standing. Non-compliance not only jeopardizes contract health but also undermines trust with government buyers. By embedding compliance into daily operations and aligning internal systems with GSA requirements, vendors position themselves for long-term growth and credibility within the MAS program.
