GSA Schedule Contract Extension – What You Need to Know about OPEN

Those that went through the GSA Contract extension process in the past know that it was often fraught with disjointed requirements and temporary extensions.  It was not uncommon for Contractors to find themselves in temporary extension purgatory for months, and in some cases even years, beyond their original contract period end date. To combat these issues, GSA began rolling out OPEN (Options Processes Ensuring Integrity) earlier this year. Its aim is to be a smooth process resulting in a unilateral modification to extend the contract. It was described at this year’s GSA Expo in San Antonio, TX as a change in mindset and approach from a “renewal” to “exercising an option.”  OPEN formalizes the milestone dates with automated email trigger dates beginning several months before the end of the contract period. It is intended to be a 250 day process with the goal of awarding the option 60 days from the end of the current term. 

The automated email trigger dates: 

• The CO & ACO both get an automated email notice 250 days from the end of contract date.
• The CO has 40 days to decide whether the contract will continue or to notify the Contractor the contract will not be extended beyond the current contract end date.
• Contractor gets automated email notice of intent to renew 210 days from the end of the contract (unless the CO has determined to not continue the contract).

OPEN has formalized the required evaluation elements, as well.  As part of the process, the CO conducts a “Fitness Assessment” of: 

• 72A Reports
• CAV Report Cards & Reports
• PPIRS
• GSA Advantage / eLibrary
• EPLS

In the past one of the biggest challenges for Contractors was that the required documentation for the extension process seemed to vary wildly by individual CO. OPEN also addresses areas that are not intended to be a part of the typical process. What is not supposed to be required? 

• Financial Determination (The CO does still have some discretion to request this if they have reason to believe that financial soundness may be an issue)
• Resubmission of Letters of Supply
• GSA Pricelists sent to CS (but upload to eLibrary / Advantage is required after option awarded)
• New CSP if there are no changes to commercial sales practices
• Signing the SF30
• Renegotiation of pricing

 It is NOT supposed to be the opportunity to 

• Make Admin changes
• Submit Bilateral Modifications (Adds, Deletes, Price changes etc.)
• Renegotiate the Contract

Source‐ GSA Expo 2012 

What is the potential impact of OPEN?

• CO confusion and consternation: The required elements of OPEN are somewhat different from (and fewer than) what COs often requested in the past. Other questions are still open: such as “When are Letters of Supply required to be resubmitted”?
• Sea change in understanding of “Renegotiation of pricing”: The new GSA stance is renegotiation of pricing is a possibility anytime a bilateral modification is requested.
• Temporary extensions

What we are actually seeing in practice:

• Last minute scrambles- The packages, in some cases, are not actually reviewed until months after submission.  Also, despite the program’s emphasis on timely extensions, we have still had instances where the extension was not actually granted until days before the end of the current contract period because of ongoing rounds of clarification.
• Requests for additional documents not listed in the OPEN package.
• System issues at GSA- Since the extension package must be submitted through eMod, issues surrounding clarifications and updated document versions are not uncommon.  These can delay the process significantly while the issues are resolved or a work-around is developed.
• Push to address other issues in separate modifications before the Option is exercised- When there are issues that must be addressed prior to an extension being granted—such as changes in commercial sales practices, pricing, adds/deletes etc.— these must done outside of the extension process.  When these situations occur we are seeing that both sides (GSA and Contractor) are struggling to manage multiple mods working through the system concurrently.

The future of OPEN:

The issues we have noticed from the Contractor-side have not gone unnoticed on the GSA-side, as well. At a recent event, a representative from GSA mentioned that this program’s main goal was to address the massive extension backlog they were struggling under but may have swung too far the other way in terms of not requiring enough information in the initial package submission to adequately review the contract. We haven’t seen any formal alterations to the package or process but expect that we will sometime soon.  Of course, once we have any new information on any changes, we will keep you posted.

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