The General Services Administration (GSA) has launched a new initiative, dubbed “Get it Right,” in an effort to ensure that GSA contracting officers and agencies using GSA contract vehicles always follow procurement rules.  The initiative is aimed at addressing several issues, including the misuse of small-business contracts and ordering work outside the scope of a contract.  It has long been the perception that contractors with GSA contract vehicles or other government-wide acquisition contracts have received millions of dollars worth of orders under those vehicles where the services or items being purchased were not within the scope of the contract or that the letter of the applicable contracting regulations was not being followed.  These abuses came to the forefront with the revelation that the Army purchased interrogation services from CACI International’s GSA IT Schedule.

GSA Administrator Stephen Perry indicated the premise of the initiative is to proactively supervise the use of GSA contract vehicles to get the best value for the taxpayer and make acquisitions in the best interest of the agency buyer. The initiative will stress, among other things, compliance with procurement rules, full and open competition and training of acquisition workforce.

Although much of the effort is aimed at fine tuning the actions of government employees, contractors also have a role to play in this initiative.  GSA Deputy Associate Administrator David Drabkin recently told Federal Contracts Report that GSA is reviewing a number of government orders under GSA contracts to determine whether the proper contract vehicle was used and the proper rules followed. The notion that contractors should not be accountable for filling GSA Schedule orders that agency officials perhaps improperly issued is not one with which GSA has much sympathy. Drabkin said, "industry has a certain responsibility to make sure their contracts are not abused." Drabkin also announced that there “will be a number of companies who receive invitations to come talk to our debarment official."  The purpose of the meetings will be to investigate what steps contractors have taken to ensure against abuse of their GSA contracts.

Contractors should be proactive in responding to this initiative.  Internal procedures should be reviewed and modified, as necessary, to ensure that orders are within the scope of the contract vehicle and all applicable regulations have been followed.  If an order falls outside the scope of the contract vehicle under which it is placed, a contractor should notify the agency placing the order and may try to save the order by requesting that the agency:

· make the necessary changes to the order to make it fall within the scope of the contract vehicle;

· place the order under another contract vehicle held by the contractor, if the order would be within the scope of such contract vehicle and the agency is eligible to purchase from the contract vehicle; or

· place the order as an open market order, though this may involve greater delay and competition.