Breakout Session # Presented by FedLinx’s Mrs. Linda Rodden, Director, GSA Compliance Dr. Tomi Bryan, President & Ge

2. Preparing for a GSA Audit: Creating Positive Outcomes Breakout Session # Presented by FedLinx’s Mrs. Linda Rodden, Director, GSA Compliance Dr. Tomi Bryan, President & General Counsel Date April 16, 2008 Time 9:40 a.m. to 10:40 a.m. 2108

3. Why You Will Be Glad You Came! • This program examines the following: • Ways to prepare for Contractor Assist Visits (CAV) • Methods for cross-checking the accuracy of reported sales and IFF payments • Understanding how to organize contract information to meet the needs of the Industrial Operations Analyst (IOA) conducting the visit • Goal: to achieve a positive outcome for your company

4. Types of GSA Audits • CAV • Visit to your company by an IOA • Follows the Contractor Assessment Initiative Report Card (Report Card) • GSA does not consider this an audit • If GSA is looking at your company records, it’s an audit • Findings are made by the IOA and submitted to your company’s GSA CO

5. Types of GSA Audits • CAV continued • If your company disagrees with the findings on the Report Card, you can provide additional information to the CO in support of your company’s claims • Pre-award audit • Conducted by the Office of Inspector General (OIG) • Usually focuses on sales data (about 12 months worth)

6. Types of GSA Audits • Pre-award audit continued • Auditors are looking to determine whether GSA is receiving best price and whether the MFC is the tracking customer • Post-award audit (Whistle-blower, just your company’s turn) • Conducted by the OIG

7. Types of GSA Audits • Post-award audit continued • Conducted by the OIG • Auditors comb through all types of data • Mission is to uncover non-compliance

8. Preparing for any Audit • Request for Data • Entrance Conference • Space and Equipment • Contact Person • Handling records requests • Conclusion

9. Preparing for a CAV • Preparing for a CAV starts long before you receive notice of a visit: • Your company should have already reviewed the requirements in the Contractor Assessment Initiative Report Card (Report Card) • The Report Card can be found at this link: http://vsc.gsa.gov/casi/New_Casi.pdf

10. Preparing for a CAV • The items identified in Category 1of the Report Card are deemed critical • Failure to meet any one (1) of these ten items will result in a rating of serious concerns exist: • Scope • Trade Agreements Act Compliance (TAA)

11. Preparing for a CAV • Failure to meet any one (1) of these ten items will result in a rating of serious concerns exist: • Pricelist being used is current & approved • System in place that identifies, tracks and reports GSA sales accurately & completely • Dealer sales are included in 72A report • Meeting sales requirement (not discussed)

12. Preparing for a CAV • Failure to meet any one (1) of these ten items will result in a rating of serious concerns exist: • System in place to monitor basis of award (BOA) customer • Pricing accuracy: Approved GSA price or lower being charged • Compliance with EPA clause

13. Preparing for a CAV • Failure to meet any one (1) of these ten items will result in a rating of serious concerns exist: • Subcontracting plan goals met/progress toward meeting them (not discussed) • Accurately identifying products that have environmental attributes

14. SCOPE • MEANING: Company sells products/services within scope of contract • METHOD: • Identify items as on contract versus open market • Have an open market section on quotes, customer acknowledgement and invoice • Program software to identify each line item as open market or on contract Must start this process long before the CAV is scheduled

15. TAA • MEANING: Products/services on Schedule must be designated country end product (See FAR 52.225-5) • METHOD: • Obtain COO information from manufacturer through LOS • Process for updating LOS information at least annually regular intervals

16. CURRENT, APPROVED PRICELIST • MEANING: Contractor is quoting to agencies using the latest GSA published pricelist • METHOD: • Process for updating and distributing the GSA published pricelist internally • Spot check invoices to confirm price charged to customer is what has been approved by GSA

17. IFF SYSTEM • MEANING: Contractor has a system in place that substantially identifies, tracks and reports GSA sales accurately and completely • METHOD: • Must be able to associate product/service sold with a specific SIN (identify SIN on order by product manually or electronically through order or accounting software)

18. IFF SYSTEM • METHOD continued: • Must be able to track each time that product/service is sold to a GSA Customer (as simple as identifying the order as a GSA order versus open market order) • Must be able to determine total amount sold by SIN on a quarterly basis (can calculate manually or electronically in ordering/accounting software)

19. BOA MONITORING • MEANING: Contractor has a system in place to monitor the "basis of award" customer discount relationship (purpose here is to avoid triggering price reductions clause (PRC) • METHOD: • Determine who the BOA customer is for your contract

20. BOA MONITORING • METHOD continued: • Determine the pricing relationship between the BOA customer and GSA • Check quotes to the BOA customer before submission to ensure price relationship is maintained (while a quote does not trigger the PRC, this is a great check point) • Check orders/awards from the BOA customer before acceptance to ensure price relationship is maintained

21. PRICING ACCURACY • MEANING: Contractor charges customers the contract price or lower • METHOD: • Hard code price into order entry/accounting software • Use only latest GSA Published pricelist if manual quote/order creation • Spot check invoices to confirm price charged to GSA customer is what has been approved by GSA

22. EPA • MEANING: Contractor is complying with the EPA clause of the contract • METHOD: • Read the contract to determine what the EPA requirements are • Every time prices change, modify the contract • Have a GSA pricing team that reviews price at least annually to determine if an EPA is required

23. ENVIRONMENTAL ATTRIBUTES • MEANING: Contractor accurately identifying products that have environmental attributes • METHOD: • Obtain environmental information from manufacturer through LOS • Process for updating LOS information at least annually

24. Federal Procurement Data System • Many IOA now pull data from FPDS for a CAV – www.fpds.gov • FPDS data has GSA orders listed and CAV will ask you to pull a specified number of orders • IOA is looking for a lifecycle of paperwork that shows company is identifying, tracking and remitting correct IFF amount • This paperwork should also identify items that are open market

25. Federal Procurement Data System • Conduct a self audit now!!! • Pull FPDS data and act like an IOA • Look for a lifecycle of paperwork that shows company is identifying, tracking and remitting correct IFF amount • Make sure this paperwork also identifies items that are open market • If your self-audit reveals misalignment with industry best practices, implement new measures that create realignment

26. Organizing Contract Information • Keep data organized • We suggest maintaining Documentation Libraries – paper or electronic • Basic Libraries include: contract award, contract modification, commercial pricelists, GSA published pricelists, GSA quotes, GSA orders, BOA orders and open market orders, IFF

27. QUESTIONS • Dr. Tomi Bryan: tbryan@fedlinx.com or 336.379.0442 • Ms. Linda Rodden: lrodden@fedlinx.com or 336.379.0442