Navigating the GSA Multiple Award Schedule (MAS) program offers tremendous opportunities for government contractors. However, it also comes with oversight, particularly audits by the GSA’s Office of Inspector General (OIG) or Industrial Operations Analysts (IOAs).
These audits can be intensive, focusing on pricing, compliance, and contract performance. To protect your business and retain your contract, it’s essential to understand common audit triggers and how to avoid them.
1. Inaccurate or Incomplete Commercial Sales Practices (CSP) Disclosures
Why It’s an Audit Trigger
Your Commercial Sales Practices (CSP) disclosures outline the pricing and discounting practices you use in the commercial marketplace. If GSA suspects that your CSP is incomplete, inaccurate, or misleading, it can prompt an audit. GSA auditors use this document to ensure you are offering fair and reasonable pricing to the government.
Common Mistakes
- Omitting customers or discounting practices
- Misrepresenting standard prices or high-volume discounts
- Failure to update CSP when pricing practices change
How to Avoid It
- Be transparent: List all customer types, discount levels, and terms.
- Maintain documentation: Keep records of invoices, agreements, and discount structures.
- Update regularly: Reassess and update your CSP during modifications and renewals to ensure accuracy.
- Review with a compliance expert before submission.
Tip: The OIG has flagged CSP issues as a top finding in GSA contract audits. Avoiding this starts with clean internal records and proactive transparency.
2. Non-Compliance with the Price Reduction Clause (PRC)
Why It’s an Audit Trigger
The PRC requires that you maintain your established pricing relationship between GSA and your designated “Basis of Award” (BOA) customer. If you give better pricing to your BOA customer without offering the same or better deal to the GSA, it’s a violation.
Common Mistakes
- Offering larger discounts to commercial customers but not to GSA customers
- Not tracking discounting practices
- Misidentifying the BOA customer
How to Avoid It
- Know your BOA customer: Clearly define and document them in your contract.
- Monitor pricing: Set up internal systems to flag when BOA customers receive better pricing.
- Document all transactions and discount rationale.
Tip: PRC violations can lead to penalties and clawbacks. Use automated tracking tools or software to stay compliant.
3. Failing to Submit the Industrial Funding Fee (IFF) or Misreporting Sales
Why It’s an Audit Trigger
You’re required to report your GSA sales quarterly and pay the IFF (currently 0.75%) on those sales. Missing reports or underreporting sales raise red flags.
Common Mistakes
- Not distinguishing between GSA and non-GSA sales
- Miscalculating IFF
- Submitting late or incomplete reports
How to Avoid It
- Train your sales/accounting team to identify GSA-eligible sales correctly.
- Set automated reminders for IFF filing deadlines (e.g., Jan 30, Apr 30, Jul 30, Oct 30).
- Reconcile sales monthly, not just quarterly.
Tip: Always keep documentation (invoices, purchase orders, etc.) for each sale. GSA IOAs often request this during audits.
4. Failure To Comply With The Trade Agreements Act (TAA)
Why It’s an Audit Trigger
TAA compliance means all products sold on the GSA schedule must be made in the U.S. or a TAA-designated country. Selling products made in non-compliant countries (e.g., China, India, Russia) is a serious offense.
Common Mistakes
- Mislabeling or misrepresenting Country of Origin (COO)
- Relying solely on supplier statements without verification
- Using third-party resellers that source non-compliant products
How to Avoid It
- Verify the COO using documentation like manufacturer certificates or bills of lading.
- Maintain a COO compliance file for every item listed on your schedule.
- Educate your procurement team about TAA-approved countries.
Tip: Countries like China and India are not TAA-compliant. This is one of the top causes of contract cancellation during GSA audits.
5. Poor Record-Keeping and Documentation
Why It’s an Audit Trigger
GSA auditors expect to see supporting documentation for pricing, sales, discounting, modifications, and compliance actions. If you can’t produce the requested documents, it signals non-compliance or negligence.
Common Mistakes
- Lacking records for modifications or sales
- Not saving pricing justifications
- Storing documents in decentralized, inconsistent formats
How to Avoid It
- Implement a centralized document management system.
- Maintain documentation for 5 years as required by the GSA.
- Use digital backups for all paper documents.
Tip: Conduct internal audits twice a year to identify documentation gaps before GSA does.
6. Inaccurate GSA Advantage! Catalog or Price List
Why It’s an Audit Trigger
Your GSA Advantage! catalog must reflect your approved pricing, product list, and terms. If your Advantage catalog differs from your approved GSA Schedule, it can trigger a compliance review.
Common Mistakes
- Posting unapproved products or prices
- Failing to remove discontinued items
- Not updating Advantage! after contract modifications
How to Avoid It
- After every contract modification, immediately update Advantage!
- Use SIP or EDI to push catalog updates accurately.
- Cross-check Advantage! regularly with your latest GSA contract modification.
Tip: IOAs use GSA Advantage! as a primary audit reference. Misalignment is a surefire trigger.
7. Ignoring Schedule Contract Modification Requirements
Why It’s an Audit Trigger
Every change to your business that affects your GSA offering, like pricing, product changes, address changes, or terms, must be submitted through a formal modification. If you act without modifying your contract, that’s a compliance risk.
Common Mistakes
- Selling new products without approval
- Changing pricing or discounts without a mod
- Changing the company name or novation without notifying GSA
How to Avoid It
- Use eMod regularly to keep your contract up to date
- Set up a contract compliance calendar to review changes quarterly
- Consult a GSA Schedule consultant if you’re unsure about needed mods
How To Prepare For A GSA Audit
Preparation goes beyond avoiding the seven triggers above. Here’s how you can stay audit-ready at all times:
Internal Compliance Checklist:
| The CSP file is current and complete | ✅ |
| PRC tracking system in place | ✅ |
| Sales and IFF accurately reported | ✅ |
| TAA-compliant product documentation organized | ✅ |
| All modifications submitted and approved | ✅ |
| GSA Advantage! catalog matches contract | ✅ |
| Employee training on GSA compliance policies | ✅ |
| Conduct Regular Mock Audits | ✅ |
Use internal or third-party resources to simulate an audit. This will reveal gaps before the GSA does.
Use Audit Management Tools
Tools like Fedmarket’s GSA FSS Management Software or GSA-focused ERP systems can automate tracking of sales, PRC changes, and catalog updates.
What Happens If You Fail a GSA Audit?
Consequences can be severe:
- Contract cancellation or suspension
- Financial penalties or clawbacks (especially for PRC violations)
- Referral to the DOJ for potential False Claims Act violations
- Reputational damage within the federal procurement space
How GSA Contract Services Helps You With OIG Audits?
GSA Contract Services has a long-standing history of helping its clients acquire and manage their GSA MAS contracts.
We provide all sorts of management services, including negotiations, price changes, catalog uploads, modifications, etc. Among them, preparing for and helping with the audit process of the GSA is one of our primary missions.
For years, we have helped our clients with different audit scenarios and cases. Here is how we do it.
Help clients with document preparation.
Preparing documents for audits is a time-consuming but necessary process. There will be thousands of documents needed to be prepared for the audits from months or even years of operations on the GSA Schedules of the business.
As we are familiar with our clients’ GSA MAS operations, we will help them prepare these documents and make sure they are ready for audits by ensuring all proper checks and solving any inaccuracies.
Doing this helps the clients focus more on growing their sales on the government marketplace, as they do not have to dedicate their time to audit document preparations.
Negotiate with GSA contract officers.
Constant communication with the COs is an integral part of any GSA Contractor. More often than not, your interactions and communications with your GSA Contracting Officer determine your audit status and readiness.
GSA Contract Services handles the difficult part of communicating with your contracting officers and details them about your contract’s current situation and its prospects. These will be an important aspect during the audit process and may even help make your audits smooth or difficult.
Support the clients with audits by interacting with OIG auditors during audits.
We, as your GSA Contracting partner, do not leave you alone during the ongoing audit processes. We will be with you every step of the way, including interacting with the OIG auditors on your GSA Schedule contracts.
As we can speak the GSA language, our support becomes invaluable to you in maintaining a good interaction with the GSA auditors, helping you in your GSA audit journey.
Leverage our experience in making the GSA Contract fully compliant with audits.
The most important part of GSA audits includes whether the business is compliant with the GSA Compliance list and if the business has violated any compliance rules. The audit mainly focuses on any compliance violations and untoward behavior that is not allowed by the GSA.
With our decades of GSA experience, we make your contract fully compliant with any and all GSA rules so that you can pass your audits with flying colors. You will have no worries with our support.
Conclusion
GSA audits are thorough, but survivable with proper preparation. Most audit triggers stem from neglect or misunderstanding rather than intentional fraud. By maintaining clean records, updating your contract frequently, partnering with consultants like GSA Contract Services, and staying honest about pricing, you’ll protect your business and thrive in the GSA marketplace.
