Top Five Failures in GSA Office of Inspector General (OIG) Audits #4, Sales Tracking Systems and Reporting

At a Glance

• Main Takeaway: GSA Multiple Award Schedule (MAS) contract holders are required to maintain sales tracking systems that segregate MAS sales, allowing for accurate and timely sales reporting and Industrial Funding Fee (IFF) remittance.
• Business Impact: Failure to comply with MAS sales reporting requirements can lead to significant business risks including financial penalties, audit findings, and potential contract cancellation.
• Next Steps: This is more than just an audit concern–every Contractor Assessment validates sales reporting, too. Contact our team today to discuss how your company can improve its MAS sales tracking and reporting procedures.

The Full Story:

The fourth in a series of articles dedicated to GSA OIG audit compliance failures focuses on MAS sales tracking systems and reporting. All MAS contractors must comply with GSAR 552.238-80 Industrial Funding Fee (IFF) and Sales Reporting. GSA does not mandate the use of specific accounting software, but the accounting system must be able to identify and track GSA MAS sales. The level of detail required about the sales depends on whether the contractor participates in the Transactional Data Reporting (TDR) pilot.

Contractors can recognize a MAS sale for reporting purposes at one of four points: receipt of order, shipment/delivery, issuance of invoice, or payment. Once a contractor selects a method, it must be used for the life of the contract. Even when there are no GSA sales during a period, contractors must still submit a zero-dollar report. Should auditors find unreported sales or inaccurate sales reports, the audit report will note deficiencies in the sales tracking and reporting processes. To resolve the finding, the contractor must submit a sales adjustment and remit any additional IFF.

What does GSA consider a GSA sale?

The IFF is a fixed administrative fee (currently 0.75%) included in the price for all products and services offered under the MAS contract. The IFF must be reflected in the total amount charged to ordering agencies. GSA’s Federal Acquisition Service (FAS), which manages the MAS program, is self-funded through the IFF. Since GSA is motivated to maximize IFF, its interpretation of what constitutes a MAS sale is broad.

GSA classifies a transaction as a reportable MAS sale if:

1. The customer is eligible to use the MAS contract,
2. The product and/or service sold is awarded on the MAS contract, and
3. There is no other contracting vehicle in place.

It is incumbent on the contractor to prove a transaction is NOT a MAS sale. If it is not clear that the procurement is under a MAS contract–or if you are at any point unsure–it is recommended to ask the ordering agency to confirm and document your files appropriately.

Identifying MAS orders can be particularly tricky for state and local sales. All MAS Special Item Numbers (SINs) are eligible for the Disaster Recovery Program, which allows state and local entities to utilize MAS for disaster preparation, response, or recovery. SINs in the Information Technology (IT) and Security and Protection categories are eligible for the Cooperative Purchasing Program, which allows state and local governments to utilize MAS at any time to purchase from these categories. State and local sales must be reported separately from federal sales using the “-RC” or “-STLOC” SINs.

Sales Reporting Requirements for Non-TDR Contractors

Contractors who are Commercial Sales Practices (CSP)-covered (i.e., not participating in TDR) must submit sales reports and remit the IFF quarterly. Sales should be aggregated at the SIN level. If an order covers multiple SINs, contractors should be able to demonstrate how the sales were allocated to each SIN.

Sales Reporting Requirements for TDR Contractors

Contractors participating in TDR are required to submit monthly sales reports and remit the IFF quarterly. Sales reports must be itemized at the invoice line-item level and include 12 required data points. For products, contractors must use the specific part number listed in the GSA catalog. For labor hour services, contractors must use the exact labor category title shown in the GSA price list, even if the invoice used task order labor category titles.

GSA does not currently have clear guidance on TDR reporting for fixed-priced orders. Until that guidance is released, contractors should report based on how the fixed price is invoiced. Since the OIG has long scrutinized the TDR program, there is increased focus on the TDR reporting accuracy.  For contracts in the FAS Catalog Platform (FCP), the system started validating TDR sales reports against the contract in January 2025.

General Guidance

Instituting a method to identify GSA sales within the accounting system, such as a GSA flag or specific naming convention, helps streamline the sales reporting process. TDR contractors may benefit from creating a custom sales report in the accounting system to use for batch uploads in the GSA Sales Reporting Portal (SRP). Remember that only sales of MAS products and services must be included in the sales report. Other direct costs, such as travel and non-Schedule items, should be excluded from the sales total.

The Bottom Line:

Accurate and timely sales reporting is not just a requirement but a critical aspect of successful GSA MAS contract management. By ensuring compliance with the sales reporting requirements, contractors can avoid potential audit findings and financial penalties. As GSA continues to emphasize the importance of accurate sales reporting, contractors must remain proactive by reviewing and updating their current sales tracking processes and procedures.

Related Resources/Assets/Aprio.com articles/pages

Aprio GSA Consultants

An Introduction to Multiple Award Schedule (MAS) OIG Audits

Top Five Failures in GSA Office of Inspector General (OIG) Audits #1, The Price Reductions Clause

Top Five Failures in GSA Office of Inspector General (OIG) Audits #2, Unqualified Labor

Top Five Failures in GSA Office of Inspector General (OIG) Audits #3, Overcharges and Overstated Rates