GSA Schedule contracts require the contractor to remit an Industrial Funding Fee (IFF) to GSA on a quarterly basis. The current IFF is 0.75% of sales. This fee is the means by which the government agency (end-user) procuring products or services on the GSA Schedule compensates GSA for the service they perform in negotiating and administering GSA Schedules. If the end-user were to procure products or services directly, they would incur additional expense in issuing RFPs/RFQs, receiving and evaluating proposals, and negotiating prices. By using the GSA Schedule, they save these additional expenses justifying the IFF.
When proposing prices for the GSA Schedule, the contractor establishes a base price which covers its costs and fee and then adds 0.75% to cover the IFF to determine the total GSA price. If the base price is $1,000, the GSA Schedule price would be $1,007.50. This is the price the contractor charges the end-user. On a quarterly basis, the contractor reports its sales to GSA and remits the IFF payment to GSA. GSA Form 72a is the normal means of reporting sales. The online reporting system takes the sales amount entered by the contractor and multiplies it by 0.75% to determine the amount to be remitted.
If the contractor uses the $1,007.50 as its sales price on the Form 72a, the online reporting system will take that and multiply it by .0075 to obtain an IFF owed of $7.56 instead of $7.50. This small difference becomes significant when sales numbers increase. The difference is paying the IFF on the IFF that’s already included in the price which is more IFF than was negotiated. To avoid paying IFF on IFF, the contractor would need to establish an internal method of calculating sales that results in a sales price for reporting purposes which when entered into the Form 72a results in an IFF owed of $7.50, the amount of IFF negotiated into the Schedule price. To do this you take the sales price paid by the end-user ($1,007.50) and multiply by 0.9925 (which is 1 minus .0075) to get a calculated sales price of $999.94. Sales of $999.94 on the Form 72a would result in a calculated IFF of $7.50 ($7.49955 rounds to $7.50).
The GSA defers questions regarding the calculation of IFF to the individual ACOs. While the above method of calculating sales for the purpose of IFF reporting is mathematically correct, I could find nothing to indicate that GSA has addressed the IFF on IFF issue and concurred with contractors reporting sales that differs from what appears on actual invoices. In the above example, the invoice to the end-user would have reflected a sales price of $1,007.50 while the sales reported on the Form 72a would be $999.94. In fact, GSAR Clause 552.238-74 provides “The dollar value of a sale is the price paid by the Schedule user for products and services on a Schedule task or delivery order.” which would be the $1007.50 price.
I suspect that most companies just “eat” the IFF on IFF as a cost of doing business with the Federal Government – anything else would raise questions in an audit. It’s something to consider when proposing GSA Schedule prices if you anticipate a high volume of sales.
Hello all,
It looks like 552.238-80 was updated this past July. How can I see what the changes are from the last revision.
We received a mod incorporating IFF not just on our FSS contract but also extending to our DAPA contract as follows:
Correction to Notice Regarding Prime Vendor Sales & Distribution and Pricing Agreements (DAPA). This modification is issued to incorporate corrections to the “Notice Regarding Prime Vendor Sales & Distribution and Pricing Agreements (DAPA)”, previously published in 65 I B Solicitation M5-Q50A-03-R8 and listed as a note to contract clause 552.238-74 Industrial Funding Fee and Sales Reporting (Jan 2016, Tailored). The language is being corrected to remove the exemption for DAPA sales and certain orders placed under the MSPV program. The revised version is titled “Notice Regarding Schedule Sales”. Please see page 2 for the text of both the old and the revised versions of the notice.
REVISED VERSION:
NOTICE REGARDING SCHEDULE SALES (FEB 2019)
The following shall be reported as FSS sales and the IFF collected and remitted:
1) Task or delivery orders referencing an FSS contract number.
2) Orders placed under a Department of Defense Distribution and Pricing Agreement (DAPA).
3) Sales under Blanket Purchase Agreements (BPAs) awarded against FSS contracts.
4) Sales of items awarded under an FSS contract and shipped to the Pharmaceutical Prime Vendor that are ultimately sold to a Federal Government activity.
OLD VERSION IN 65 I B SOLICITATION M5-Q50A-03-R8:
Note: Prime Vendor Sales & Distribution and Pricing Agreements (DAPA) (Dec 2017)
Sales of items awarded under an FSS contract to a Government prime vendor that are ultimately shipped to a Federal Government activity qualify as FSS sales; therefore, these sales must be reported as FSS sales and the IFF collected and remitted. This includes sales of items awarded on the VA Strategic Acquisition Center’s Med Surge Prime Vendor (MSPV) program via Blanket Purchase Agreements (BPAs) against FSS contracts. The following are sales that shall not be reported as FSS sales; therefore, an IFF subject to FSS contract terms and conditions shall not be collected and remitted: 1) orders placed under a Department of Defense Distribution and Pricing Agreement (DAPA), and 2) orders placed under the MSPV program when the orders are placed under an Indefinite Delivery type contract that was not solicited and awarded under FSS (i.e. as an open market procurement).