GSA Schedule Audit Support

GSA has recently increased the frequency in which it performs both its mandatory Contractor Assistance Visits and OIG pre-awarded audits.

Oftentimes these events are triggered by suspected violations of GSA’s price reductions clause (GSAR 552.238-75) or when a “whistleblower” reports suspected misconduct. Unfortunately in most cases, the Contractor subject to the investigation has no idea that they have violated the regulations set forth in their GSA Schedule Contract.

Our GSA Schedule audit support engagements will help GSA Schedule contractors prepare for and respond to GSA Schedule investigations. Utilizing Attorney-client privilege, our audit engagement are tailored to your sensitive contracting needs and timelines.

Benefits Include:

  • Attorney–client privilege that protects and keeps communications confidential.
  • Expertise to address audit trends in government contracting where high risk exists.
  • Quickly identify, stopgap, and fix many non-compliance areas during process.
  • Update corporate documentation and processes to be in conformance with current Federal Acquisition Regulations (FAR).
  • Can reduce contractor’s legal and financial exposure in whistleblower (Qui-tam) cases and government OIG Audits.
  • Can improve contractor’s position on potential suspension and debarment actions.

Typical Compliance Areas Include:

  • GSA Schedule: Commercial (Basis of Award) Pricing Compliance
  • GSA Schedule: GSA Pricing and Terms Compliance
  • Small Business Subcontracting Plan Compliance
  • Services, Labor, and Ethics Compliance
  • Product and Trade Agreements Act Compliance
  • Small Business Representation and Affiliation Compliance

Project Phase I

  1. Document and process discovery
  2. “Quick fixes” to solve less difficult problems
  3. Identification of potential credible evidence
  4. Recommendations and proposed strategies

Project Phase II

  1. Remediation of deficiencies and pricing control systems
  2. Update policies and procedures
  3. Disclosure obligations under the Mandatory Disclosure Rule
  4. Employee training


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