As a VA Schedule contractor you are required to adhere to all contract requirements, as outlined in the solicitation, and submit all deliverables by the specified due date.
I-FSS-639 Contract Sales Criteria Clause
Your company must accrue at least $25,000 of VA reportable sales during the first 24 months of your contract, and maintain an additional $25,000 in sales each year thereafter.
In accordance with 552.238-73, Cancellation, the government may cancel your firm’s contract unless reported sales are at the levels specified.
Quarterly Sales Report & Remittance of the Industrial Funding Fee
All VA Schedule contractors are required to submit a quarterly sales report and IFF remittance within 60 days after the end of each quarter.
Both the sales report and IFF payment can be made through the VA Sales Reporting System.
If no sales have occurred under your firm’s Schedule contract you are still required to submit a sales report indicating $0.
For more information and instructions regarding the quarterly sales report or IFF remittance visit the Sales Reports & IFF page.
Electronic Subcontracting Reporting System
Federal contractors that are a large business and the estimated dollar value of their awarded contract is $650,000 or more are required to establish and maintain an acceptable subcontracting plan.
All subcontracting plan goals and achievements must be reported via the Electronic Subcontracting Reporting System (eSRS).
If your contract includes a “commercial” subcontracting plan, you must submit a Summary Subcontracting Report (SSR) by October 30th each year. Additionally, all plan holders must submit a Year-End Supplementary Small Disadvantaged Business Report, required within 90 days of submitting the SSR.
Download a sample subcontracting plan template and instructions on submitting the required eSRS reports via the Small Business Subcontracting Plan page!
Contract Policies and Obligations
There are many significant polices and obligations pertaining to your awarded VA FSS contract of which your firm must be aware; the following highlights a few of these. For any advice or clarifications contact your assigned contract specialist or the VA FSS Help Desk.
- Maximum Orders. Schedules contractors are obligated to accept any order from an executive agency that is below the Maximum Order threshold. Outside of the executive branch, a contractor is encouraged, though not required, to accept an order under this threshold. For orders over the Maximum Order threshold, agencies will generally expect a price break due to the large volume of the sale. Maximum order threshold is determined on a schedule by schedule or sometimes on a SIN by SIN basis. Visit the Commodities, Pharmaceuticals, and Services pages for a complete listing of the Maximum Order Thresholds under the VA Schedule Program.
- What Qualifies as a Schedules Sale? If the task or delivery order references the FSS contract number, then the entire order should be reported as an FSS sale (this includes sales made under prime vendor, direct-to-patient, and consignment programs). Non-FSS line items must be annotated as “open market” or “not under contract” and the sales value of these items should be excluded from reported FSS sales. Additionally, if the product or service falls within the description of the SINs on your contract and the customer is an eligible ordering activity, the order is considered a Schedule sale, although, in some cases, the ordering activity may indicate open market exceptions to this. You must have a tracking system and methodology in place that allows you to differentiate between Schedule and non-Schedule sales. Contractors are reminded that proper and timely sales reporting is a contract requirement.
- Price Reductions. VA FSS contractors must maintain an approved tracking customer discount relationship. If you lower your commercial prices to the contract tracking customer, you are obligated to make the same percentage reduction for your Schedules contract. Exceptions to price reductions are outlined in FSS contract clause 552.238-75 Price Reductions.
- Trade Agreement Act (TAA). The federal government maintains a list of countries with which it has trade agreements. If a country does not have a trade agreement with the United States, then you may not provide these products or services on your GSA Schedules contract. The TAA states that all products purchased by the government must be manufactured or “substantially transformed” in the United States or in one of these listed countries. The TAA pertains to all Schedules contract sales.
- TAA Compliance Settlement - The U. S. Department of Justice recently resolved a case against a large medical supply company based upon allegations that they violated the False Claims Act by making false statements to the U.S. Department of Veterans Affairs (VA) and the U.S. Department of Defense (DoD) regarding the country of origin of certain products sold to the United States. Access the full press release.
- Government Purchase Card. Schedules contractors must accept the government purchase card for all sales up to $3000.