FAS Should Strengthen Its Price Analyses When Consolidating Multiple Award Schedule Contracts

Date Issued

Monday, September 30, 2024

Submitting OIG

General Services Administration OIG

Other Participating OIGs

General Services Administration OIG

Agencies Reviewed/Investigated

General Services Administration

Report Number

A230040Q3P24002

Report Type

Audit

Agency Wide

Yes

Number of Recommendations

Questioned Costs

Funds for Better Use

Open Recommendations

This report has 3 open recommendations.

Recommendation Number	Significant Recommendation	Recommended Questioned Costs	Recommended Funds for Better Use
1	Yes	$0	$0
We recommend that the FAS Commissioner establish an oversight process for CSP-based contracts undergoing consolidation to ensure contracting personnel: (a) comply with General Services Acquisition Regulation 538.270-1, Evaluation of offers without access to transactional data, and FAS Policy and Procedure 2021- 05, Evaluation of FSS Program Pricing; and gather supporting documentation to determine a contractor’s most favored customer pricing for use in negotiation objectives; and (b) evaluate supporting documentation to verify a clear and relevant relationship between supporting documentation and each of the proposed prices it is meant to substantiate.
2	Yes	$0	$0
We recommend that the FAS Commissioner establish an oversight process for TDR pilot contracts undergoing consolidation to ensure contracting personnel do not rely solely on contract-level pricing tools; and, if prices paid data is not available, prioritize obtaining recent invoices or other than certified cost or pricing data from the contractor before relying on non-prices paid information.
3	Yes	$0	$0
We recommend that the FAS Commissioner re-evaluate previously consolidated MAS contracts to ensure that added products or services were evaluated to meet federal regulations and GSA policy requirements.