Baker Tilly’s government contractors advisors examined the disconnect between services contracting and the GSA contracting model during a NCMA webinar. Attendees gained insight into the pricing and compliance challenges faced by services contractors, and some best practices for addressing those challenges. Key points of discussion included labor category mapping, pricing strategies, commercial sales practice disclosures, obligations under the Price Reductions Clause (PRC), and GSA Office of Inspector General audits.
The presentation also highlighted the following post-award contract administration and compliance best practices:
- Save everything: Maintain documentation supporting commercial sales practice disclosures, including a mapping from internal or project-specific labor categories to GSA labor categories.
- Dig into the data: Performing a historical pricing analysis is one of the most important steps GSA contractors can take to protect themselves. A data driven review of sales practices allows a company to ensure the accuracy of its commercial sales practice disclosures, which can mitigate risks associated with defective pricing risk. An accurate and complete disclosure of commercial sales practices will mitigate risk, but it might also lead to more difficult and protracted pricing negotiations. Take steps during the aforementioned historical pricing analysis to get ready for negotiations. Capture information that will allow you to identify non-comparable sales and deviations from standard commercial sales practices.
- Clarity is King: Pricing and PRC monitoring for services contracting can be very complicated. Contractors should ensure that they clearly explain how pricing was developed, how it will be updated, and how basis of award sales will be monitored for PRC purposes in a pricing narrative that accompanies their CSP disclosures.