1. GSA OIG Audit Support
The Office of Inspector General helps GSA manage the taxpayer’s money efficiently, by ensuring effectiveness and economy, while preventing fraud and ineffective expenditure of the federal budget. One of the ways OIG accomplishes this is a GSA OIG Audit.
GSA Contract OIG Audits
- Overbilling. A common example is overbilling due to inadequate labor rates or overstated qualification of employees.
- Overpricing. The rule of thumb is that GSA prices must be lower than the commercial prices, so if the commercial price goes down, but the GSA price does not, the contract becomes non-compliant.
- Inaccurate Commercial Sales Practices. CSP Information must be complete and accurate.
- TAA incompliance. At least 50% of the monetary value of your products must originate from the U.S. or the designated countries.
- GSA Schedule sales reporting issues. As a GSA contractor you must report sales regularly.
- Industrial Funding Fee reporting issues.
The above non-compliances may result in unwanted consequences for your GSA contract, such as refunds, price reductions, change in the award basis, and even complete cancellation of the contract.
How often does GSA OIG Audit occur?
GSA OIG Audits are rare, but exactly how rare? In our experience, GSA OIG conducts approximately 40-50 pre-award audits annually. Larger volumes of sales within the GSA Schedule contract increase chances of an audit. Also, OIG audits may be initiated by the GSA in case there is either some suspicion or a particular cause for such an audit. However, the majority of OIG checks are just random, which means any contractor can face one sooner or later.
As a result, GSA OIG Audit support is highly demanded among GSA contractors who wish to ensure compliance and long-term stability of their GSA Schedule contracts.
How GSA OIG Audit is conducted
The OIG audit involves examination of contractor’s transactions, financial statements, regulatory documents and assessment of internal controls. Also, a GSA OIG inspector may interview any employee at your company that happens to be in charge of such matters.
- Sales transaction data, such as customer, contract number, invoice number, price, quantity etc.
- Any books, papers, documents and records justifying transactions within the given GSA Schedule contract.
- Commercial and GSA pricelists.
- GSA sales reports.
- Up to 12 months of previous sales data.
- List of your major non-GSA clients.
- Identification of the basis of award customer.
- Price Reductions and discounts.
- Written policies and procedures on sales reporting, processing of orders, commercial practices and so on.
- Labor rates and categories.
Overall, the process of an OIG Audit involves several steps. At first, an auditor gathers all the required information (see above), either through electronic channels or directly. The data for analysis also include prior OIG reports, if any. Among the entire volume of data, the auditor chooses a sample of transactions for in-depth analysis. For this sample, additional information may be requested.
Then, within a week or so a site visit is scheduled. The inspector visits the facilities and offices of the company, interviews officials, provides questionnaires, gathers computer data, and so on.
The final stage is analysis of the data. The result of this stage is an OIG Audit report that incorporates problems the audit team has revealed and recommendations to fix them.
Note, however, most of the issues can be fixed preliminarily if you order a GSA OIG Audit support.
Get Expert Help to Successfully Navigate Your GSA OIG Audit
Price Reporter offers full-service GSA OIG Audit support to businesses. We help you get ready for the audit, passing it without risks, or minimizing negative consequences of the audit if there would be any.
- rehearse each step of the anticipated audit to make sure the personnel understand the entire process and know what to do;
- help you recognize exactly the bottle-necks that can potentially lead to penalties;
- prepare documental proofs and explanations for transactions that seem out of place or non-compliant;
- instruct personnel in charge how to successfully pass interviews with the inspector;
- prepare ready-to-use scripts and response templates, to properly answer to the inspector’s questions and fill-in questionnaires correctly;
- thoroughly review documents to be submitted to GSA OIG Audit team;
- attend on-site OIG Audit inspections and offer support during them.
Also, our experts will participate in pre-audit meetings with the GSA OIG to help you arrange the most convenient timing and scope of the audit, as well as to help you establish good relationships with the inspector.
GSA Contractor Assessment Visit Support (IOA / CAV)
What is the GSA Schedule Audit?
Unlike GSA OIG Audits, the GSA conducts Virtual Annual Assessment for all GSA Contract Holders. During these assessments the Contracting officer conducts in-depth analysis of contractor’s business operations, in order to determine contractor’s compliance with GSA regulations and identify areas of improvement if any issues are found, with further verifications.
What is the purpose of the GSA Schedule Audit?
The purpose of Contractor Assessment is to inform GSA contractors about potential weaknesses in their contracting processes that can further lead to non-compliance or violation of GSA regulations, and to help them address these problems.
One of the main areas of concern for the Contracting Officer is confirming that the contractor is maintaining the Basis of Award (BOA), which means that the government is receiving the promised discounts in comparison to commercial or most favored customers (MFC). The contractor is responsible to maintain the negotiated relationships and if any changes occur, the contractor must perform a modification to rectify the difference created.
For example if Contractor promised GSA 10% discount from the commercial price of $100 per unit, then GSA price should be $90, and if the commercial price goes down to $70 later in time, then the contractor should also reduce their GSA price down to $63 instead of $90 negotiated originally. Otherwise the contractor must pay the difference in fines per each item overcharged.
How Contractor Assessment Visits are conducted
The assessment starts with the Industrial Operations Analyst assigned to your contract contacting you by e-mail with the notification about the upcoming CAV and the list of required documents to assess. The email will also preliminarily schedule the date of the actual visit. Contractors are required to provide all requested documents and reports.
Then, the GSA contracting officer (CO) will analyze all documents provided by the contractor, and schedule a time to review everything on video conference call with screen sharing. During the call, GSA CO will go over all their findings and ask any questions they may have remaining, to provide the contractor with an opportunity to explain the issue, before including it in the annual report to be resolved in the future.
After the video conference call is complete, the contracting officer will evaluate their findings once again, and issue an assessment report with their score and applicable notes, with recommendation for improvement.
- Basis of Award (BOA) Compliance
- Pricing compliance
- Trade Agreements Act Compliance
- Sales Reporting/IFF Payment
- Additional Discount Adherence (prompt payment, volume, etc. if applicable)
- Labor Category Qualifications Compliance (if applicable)
- Adherence to established delivery terms
The report will be ready in a week or two after the CAV. Usually a contracting officer will also assign a timeframe for the contractor to correct the issues found, or otherwise they will be reviewed in the next assessment.
How frequent CAVs are?
Before 2014, Contractor Assistance Visits were conducted at least twice for each GSA contract holder: first time assessment was scheduled between 12 months and 18 months of the contract term, and the second one was typically scheduled about 12-18 months before the end of the contract.
- How much revenue a GSA contractor generates. A threshold of $150,000 in revenue triggers annual assessments.
- Complaints or suspicions of GSA regulation violations.
- Previous assessment compliance issues.
- “Problematic” Schedules or historical issues with similar vendors.
GSA Schedule Audit Support
Price Reporter offers GSA Schedule Audit support. While CAV has no subpoena power and thus may not seem so menacing in comparison to OIG Audit, we still recommend taking it very seriously. The Contractor Assessment Visit is here to assist you in eliminating any potential problems that your company as a GSA Contractor may be experiencing, so you should not wait until these potential issues become real violations of GSA Schedule contract regulations.
- Price Reporter helps you efficiently prepare for upcoming CAV by reviewing the documents IOA will be most likely interested in.
- We will train you to set up procedures and processes, so as to avoid potential problems after a GSA Schedule audit.
- Our specialists will assess your commercial and GSA pricelists to point out potentially dangerous places that may look suspicious to the IOA.
- Rehearsal of videoconferencing calls will help you prepare yourself for online assessment.
Overall, our engagement in the GSA Schedule Audit process mitigates risks during GSA Schedule Contractor Assessment Visits or Virtual Assessment, while serving the best interests of your company.
Even though CAV is not technically an audit, and it does not have any subpoena power, if you are not prepared well for this process, you may end up with an adverse report that may affect the renewal eligibility of your GSA contract in the future. That is why paying attention to the GSA Contract Assessment is crucial, and Price Reporter is right here to guide you through the entire process.
Contact Price Reporter now for GSA Schedule Audit Support
Whether it is an OIG Audit, a Contractor Assessment Visit or a Virtual Annual Assessment, Price Reporter’s experience and expertise are at your service. If you need assistance on how to instruct your team and prepare required documents for a forthcoming contract assessment or an Office of Inspector General Audit, please don’t hesitate to contact us.
