Common GSA Compliance Violations and How to Fix Them

Common GSA Compliance Violations and How to Fix Them

Most GSA compliance violations fall into a small number of recurring categories. They are rarely the result of intentional misconduct — they typically stem from inadequate processes, missed deadlines, or misunderstanding of ongoing obligations. Understanding the most common violation types and how to correct them before a CO identifies them is the essence of proactive contract compliance management.

The Five Most Common Compliance Violations

1. Missed 72A Reports: Failing to submit quarterly sales reports and IFF payments. Fix: submit all outstanding reports immediately, pay all IFF owed plus any applicable interest, and explain the cause in a written communication to your CO. 2. Price Reduction Clause Violations: Failing to notify GSA within 15 days of offering better pricing to your BOA customer. Fix: conduct an immediate review of your commercial pricing history post-award, notify the CO of any unreported reductions, and propose a retroactive remedy for the affected period. 3. TAA Non-Compliance: Selling products of non-designated country origin on your Schedule. Fix: audit your current catalog for TAA compliance, remove non-compliant items immediately via eMod, and evaluate whether a refund or credit is owed for past non-compliant orders.

4. Lapsed SAM.gov Registration: Failing to renew annual SAM.gov registration. Fix: renew immediately at sam.gov, notify your CO once active, and in the future set 60-day calendar reminders before expiration. 5. Unauthorized Price Increases: Raising Schedule prices without CO approval. Fix: submit a modification to return prices to approved levels, and prospectively request CO approval for any future increases with supporting documentation.

Verified against official GSA and FAI sources, March 2026. Program rules, thresholds, and solicitation details are subject to change without notice.

GSA Compliance Obligations That Contractors Frequently Underestimate

MAS contract holders face ongoing compliance obligations that extend well beyond the initial award. The three areas where contractors most commonly accumulate non-compliance exposure are: sales reporting (Industrial Funding Fee remittance), Trade Agreements Act (TAA) compliance, and Price Reduction Clause (PRC) monitoring.

Sales reporting requires quarterly submission of all MAS sales through the FAS Sales Reporting Portal. The report must include all sales made under the contract — not just sales through GSA Advantage! but also direct orders issued against your contract number by federal buyers. Under-reporting, even if unintentional, creates liability that GSA may pursue during an audit.

What Happens During a GSA Contract Audit

GSA's Inspector General and the Office of Acquisition Operations conduct periodic post-award audits of MAS contractors. Audits typically focus on whether your offered prices during negotiation accurately reflected your commercial pricing practices (CSP-1 accuracy), whether you have properly reduced prices when the Price Reduction Clause was triggered, and whether TAA-compliant products are in fact manufactured in designated countries.

The most significant audit finding in recent years has been CSP-1 inaccuracy — contractors who negotiated their MAS prices based on disclosed commercial pricing that was higher than their actual commercial pricing. Settlements in these cases can require repayment of the price difference across all government sales. Maintaining contemporaneous records of your commercial pricing and discount practices is the strongest protection against adverse audit findings.

Practical Guidance for GSA Schedule Contractors

Federal contracting professionals who work with the GSA Schedule program on a regular basis develop a practical understanding of how to manage contracts efficiently while staying compliant. Here are key operational practices that consistently improve outcomes for both new awardees and experienced contractors renewing or expanding their schedules.

Document everything contemporaneously. GSA audits often occur years after the initial award, and the auditors will request records from the period of negotiation and early contract performance. Maintain organized files of all pricing justifications, CSP-1 disclosures, and negotiation correspondence. Companies that cannot produce these records during an audit face a much higher settlement risk than those who can demonstrate their pricing was accurately disclosed.

Assign a contract compliance owner. Many GSA contractors experience compliance issues because no specific individual owns the ongoing obligations. Designate one person as the GSA contract administrator responsible for monitoring sales reporting deadlines, acknowledging mass modifications, tracking price reduction clause triggers, and maintaining SAM.gov registration currency. This single point of accountability prevents the "everyone assumed someone else handled it" failures that generate the most costly compliance findings.

Build a GSA-specific rate review into your annual planning cycle. Review your GSA Schedule rates at least annually against your current commercial pricing and market rates. If your commercial rates have increased, you have the opportunity to submit a price modification that increases your GSA rates. If market rates have dropped significantly below your GSA pricing, you may be losing orders to competitors — a voluntary rate reduction can restore competitiveness. Proactive rate management keeps your contract a productive revenue channel rather than an administrative burden.

Contractors who invest time in understanding the specific procurement culture of their target agencies — their preferred contract vehicles, their incumbent contractor relationships, and their annual budget cycles — consistently outperform those who treat all federal buyers as interchangeable. Agency acquisition forecasts, published annually by most major federal agencies, provide detailed insight into upcoming requirements that can be matched against your MAS SINs and capabilities. Incorporating these forecasts into your marketing planning turns reactive RFQ responses into proactive relationship-building that positions your firm as a known quantity before solicitations are released.

Next Steps

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GSA Schedule information changes as acquisition regulations are updated. Verify current requirements at gsa.gov/acquisition/gsa-schedules and sam.gov before making contracting decisions.