Contractor Support: GSA’s New Directive on EPA Adjustments

The General Services Administration (GSA) has taken a significant step to provide flexibility to contractors facing economic uncertainties. On March 17, 2022, the GSA announced a temporary moratorium on certain limitations within the GSA economic price adjustment (EPA) contract clauses. This initiative aims to ease the challenges contractors face in adapting to changing market conditions while ensuring continued support for their federal customers’ requirements. 

You may read the announcement here.

Details of the Temporary Moratorium 

During this period, the GSA’s policy moratorium introduces several key changes to EPA contract clauses. One notable adjustment is the relaxation of time limitations on EPA increases, granting Contracting Officers (CO) the authority to consider more than three EPA modifications in a contract period. Additionally, COs have the flexibility to entertain EPA modifications that exceed the ceiling clause, subject to a lower level of approval. 

Key Policy Changes for Contractors 

Contractors can benefit from the moratorium in various ways. They now have the option to add items previously removed from their Multiple Award Schedule (MAS) contract at a higher price, provided the higher price is deemed fair and reasonable. However, COs retain the right to reject modifications if they determine the price is not fair and reasonable, maintaining a balance between flexibility and accountability. 

Implementation and Duration 

The temporary moratorium became effective on March 17, 2022, and is scheduled to continue until the end of the GSA’s fiscal year on September 30, 2022. The possibility of an extension exists, and stakeholders are advised to stay informed about updates from the GSA. 

GSA’s Announcement Update: Extension and New End Date 

In a recent update, the GSA announced an extension of the moratorium, pushing the end date to September 30th of the current year. This extension reflects the GSA’s commitment to providing ongoing support to contractors navigating economic challenges. 

How Contractors Benefit from the GSA’s Initiative 

Contractors can leverage the temporary moratorium to adapt to changing market conditions and ensure seamless support for their federal customers’ requirements. The flexibility introduced minimizes bureaucratic hurdles and potentially saves time and effort for contractors seeking EPA modifications. 

CO Approval Process during the Moratorium 

The lower level of approval required during the moratorium streamlines the process for contractors seeking price increases above the EPA clause ceiling. Understanding the implications of this change is crucial for contractors aiming to navigate the modified landscape effectively. 

Ensuring fair and reasonable prices remains a priority during the moratorium. Contractors should be mindful of the conditions for price determination and the potential rejection of modifications if prices are deemed unreasonable. The GSA is committed to keeping stakeholders informed and addressing concerns transparently. 

Assistance for GSA Price Increases 

Contractors seeking assistance with GSA price increases are encouraged to reach out to the GSA team. Proactive communication can save time and reduce the chance of rejection, ensuring a smoother process for contractors navigating the complexities of EPA modifications. 

Conclusion 

In conclusion, the GSA’s temporary moratorium on EPA restrictions signifies a proactive approach to support contractors in a dynamic economic landscape. The extension of the moratorium demonstrates the GSA’s commitment to adapting to evolving challenges and providing essential support to its stakeholders. 

Frequently Asked Questions (FAQs) 

Q: Why did the GSA implement a temporary moratorium on EPA restrictions? 

  • A: The GSA implemented the moratorium to provide flexibility to contractors facing challenges in adapting to changing market conditions. 

Q: Can contractors add previously removed items back at any price during the moratorium? 

  • A: Contractors can add previously removed items back at a higher price if the higher price is determined to be fair and reasonable. 

Q: What is the lower level of approval required during the moratorium for price increases? 

  • A: Just one level above the Contracting Officer is needed for price increases above the EPA clause ceiling. 

Q: Is the moratorium on EPA restrictions subject to extension beyond September 30, 2022? 

  • A: Yes, the GSA has the option to extend the moratorium, and stakeholders are advised to stay informed about updates. 

Q: How can contractors get assistance for GSA price increases? 

  • A: Contractors can reach out to the GSA team for support, minimizing the chances of rejection and saving time in the process. 
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Cristi Suhadolnik
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