2) Is It Time to Update the Pricing on Your GSA Schedule?
There is a very good chance that if you have had a GSA Schedule
contract for 12 months or longer, your pricing on the Schedule
is outdated. Indeed, some vendors find that their pricing
requires updating nearly as soon as the contract is awarded.
The GSA Schedule program awards contracts to vendors for
Commercial Off The Shelf products and services. Key to the
government’s price evaluation for these products and
services are two components: how the vendor sells in the commercial
marketplace, and (to a lesser extent) pricing of similar products
and services already available to the government.Each GSA
Schedule contract award utilizes a Basis of Award Class of
Customer and pricing relationship that must be maintained
throughout the life of the contract.
Two mechanisms for updating pricing are the Economic Price
Adjustment (EPA) and the Price Reduction clauses. While both
of these clauses can be found in the Federal Acquisition Regulation
(FAR) and are incorporated into the GSA Schedule contracts,
both may be modified through negotiations at contract award.
The EPA clause contemplates increases to pricing. Increases
for products are generally based on adjustments made by the
vendor to the Basis of Award pricelist. However, each GSA
Schedule solicitation differs as to how much and when the
increases are allowable. With services, the EPA depends upon
the specific solicitation and whether the services are professional
or covered under the Service Contract Act. Generally, an EPA
is feasible after a labor category has been under contract
for 12 months. If a labor category is covered under the Service
Contract Act, government alteration of the wage determination
is cause for requests of appropriate adjustments. Price increases
for services may be submitted 30 days in advance of the 12-month
anniversary date.
The Price Reduction Clause, as its name suggests, lays out
the triggers and procedures for lowering prices to the government.
Price Reductions may be Permanent or Temporary. While Price
Reductions become effective in coordination with the commercial
pricing, they must be approved by your Procurement Contracting
Officer (PCO) at GSA. In general, price reductions are triggered
by changes in the commercial pricing to the Basis of Award
Class of Customer, whether on the published pricelist or through
commercial selling practices.
It is important to provide routine education to the sales
and management teams monitoring the pricing of your products
and services on the GSA Schedule and in the commercial marketplace.
EZGSA recommends that all schedule holders perform an annual
compliance review to ensure that the company’s practices
are in accordance with the contract.
If you have any questions about pricing modifications or
GSA Schedule compliance related issues, please contact Ms.
Judith R. Nelson, Director of Government Contracts at
jnelson@ezgsa.com or 301/913-5000 ext. 5010.
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