GSA FAS TTL QMAAB MAS Industry Day Questions Answers 2024_07_05.pdf

MAS Industry Day – 06/25/2024

Questions and Answers

1. GSA requires past sale for pricing support. Does it mean you can sell the item in the open market?

Response: Yes, GSA requires that you provide pricing support documentation along with any eMod request associated with products or services. Yes, you can sell any item offered by your company in the “open market” and provide the pricing support documentation from those sales to

GSA.

2. Would Government quotes be considered in lieu of commercial quotes? Pricing quoted to a government’s customer who needs to get funding approved prior to an item being added to a MAS contract?

Response: Yes, GSA will accept pricing support documentation from sales with other Government customers, such as purchase orders or invoices. If you are quoting the item for the very first time to a potential commercial or government customer, the quote may not be sufficient to substantiate your modification request to add the item to your MAS contract. In addition to quotes/sales to government customers, in some instances, we may request commercial support documentation to confirm the pricing charged to your commercial customers.

3. You mentioned that GSA may require past sales via GSA for pricing support. Does that mean we can sell open market items on GSA for future GSA pricing support?

Response: An “open market item” is a product/service that is not awarded on a GSA MAS contract. If an item is not awarded on your GSA MAS contract, then you can quote any price for that item. However, if an item is awarded on your GSA MAS contract, then you must offer/quote the GSA MAS contract awarded price for that item during a competition (although you can offer a discount from that price). Please also see FAR 8.402(f) for additional guidance about including open market items with a GSA Schedule order. Sales of items on the open market can then be used for pricing support for future add product GSA MAS modification requests.

4. Let’s say we are in the process updated our pricing - can we send us our marketing information and submit to CS that we have found that are readily available in order to have the modification approved for the price increase?

Response: If you have updated marketing information that supports the proposed price for an item that you are offering to GSA, you can provide that information, which will be reviewed.

Depending on the information included in the marketing material, it may or may not provide adequate pricing support. Please note that GSA does not require that you create new marketing materials for the products/services that your company offers. However, if you have marketing material that you publish for your business, then certainly you can provide it with your contract modification request.

5. What is the difference when using the new FAS platform? How many vendors have migrated to the new platform?

Response: Whether a MAS contract is signed up for the new FAS FCP application or not, the requirement to provide pricing support documentation is the same. Currently, our organization has transitioned about 100 MAS contracts to the FAS FCP application.

6. When does the EPA moratorium end?

Response: On February 28, 2024, GSA issued Supplement 4 to Acquisition Letter MV-22-04.

The policy extends a moratorium on the enforcement of certain limitations contained in certain GSA economic price adjustment (EPA) contract clauses to December 31, 2024. Of course, the better the pricing support documentation provided to GSA, the easier it will be to determine that the proposed pricing is fair and reasonable.

7. I have around 80 base products and maybe 200 options to build a custom trailer, if there is one item a GSA customer needs for that trailer and it's not listed on my contract, can I sell that option on the same invoice or do I have to keep that option separate?

Response: Yes, if you have a sale of “open market” items and “GSA MAS contract” items included in one transaction both items can be cited on the same company invoice. However, the “open market” item must be labeled “open market” so that it is clear and will not be reported to GSA as a sale. Please also see FAR 8.402(f).

8. So hypothetically, I raise prices on my commercial price sheet by 50% for some random reason. What is the reason I cannot increase my GSA price by the same? If I’m overpriced and don’t sell anything it is my problem not GSA’s, right?

Response: GSA does not prohibit you from raising the prices for products and services offered by your company if you can support the increase with appropriate documentation and if GSA is able to find the proposed pricing fair and reasonable. The decision to raise the prices for your company products and services is your business decision alone. GSA understands that a company must check the marketplace and any competitors’ pricing to determine how the company’s pricing compares to the marketplace. GSA understands that if the products or services included on your GSA MAS contract must be adjusted, that a contract modification will be submitted to GSA to request your contract pricing be adjusted accordingly. When GSA receives a modification request to increase the pricing for products or services on your MAS contract, the pricing support documentation will be considered during the evaluation of the proposed pricing.

Since GSA Advantage/eLibrary are used for both ordering and market research, GSA does care very much about the pricing that is published there.

9. I’m finding out-of-date pricing from other contractors on GSA Advantage that looks unreasonably low. Don’t other contractors have to honor their prices that are published on GSA Advantage?

Response: All GSA MAS contractors are required to maintain up-to-date pricing posted to the GSA Advantage and eLibrary websites. As “add product” and “economic price adjustment” modifications are initiated by the vendor, not all vendors meet this requirement as not all vigilantly keep their product and pricing information on these sites current. If the contract pricing published is outdated, the contractor should submit a contract modification in eoffer/emod to make the necessary pricing adjustments. GSA always encourages MAS contractors to be proactive in maintaining their pricing at GSA Advantage and eLibrary.

https://www.gsa.gov/system/files/MV-22-02%20with%20sups%201-4.pdf