By Craig Stetson CPA, CGMA
Director | Government Contract Regulatory Compliance Practice
A recently issued DPAP memo reiterates the requirement that COs perform adequate price reasonableness analyses when placing orders off GSA Schedules. This memo was released as government purchases, GSA Schedule or otherwise, typically increase significantly during the last quarter of the government fiscal year. An underlying message of this memo is that a contractor’s price offered on a GSA Schedule cannot automatically be deemed fair and reasonable solely because the corresponding item or service is included on a GSA Schedule. The memo also addresses procedures required when purchasing open market items (items not included on a GSA Schedule). http://www.acq.osd.mil/dpap/policy/policyvault/USA004263-15-DPAP.pdf
Although this instruction was issued to government COs, it has relevance on the contractor side as well related to their (contractors) purchase of goods or services from GSA Schedules. The points noted in this memo should be considered in conjunction with development / administration of contractors’ overall purchasing system policies and procedures.
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