Contract Management
Opportunities Continue for GSA to Improve Pricing of Multiple Award Schedules Contracts Gao ID: GAO-05-911T July 26, 2005Each year, federal agencies spend billions of dollars to buy commercial products and services through the General Service Administration's (GSA) Multiple Award Schedules program. The program has grown significantly over the past several years. Currently, federal agencies can directly purchase, through more than 16,000 schedule contracts, over 8 million products from more than 10,000 commercial vendors. In fiscal year 2004, purchases from these contracts totaled more than $32 billion. The multiple award schedules program is designed to take advantage of the government's significant buying power. To maximize savings, GSA negotiates discounts that are equal to or greater than those given to the vendor's most favored customers. This testimony focuses on GSA's historic use of two proven negotiation tools to improve the pricing of schedules contracts--pre-award audits and postaward audits of pre-award information. Pre-award audits allow GSA to avoid potential overpricing by verifying vendor pricing information before contracts are awarded. Postaward audits allow GSA to identify overpricing of awarded contracts and recover overcharges.
Historically, GSA has used pre-award and postaward audits sporadically, thereby minimizing its ability to avoid excessive pricing and recover overcharges and potentially save millions of federal dollars. For more than 25 years, GAO has reported on GSA's multiple award schedules program pricing problems. In March 1977, we reported that pre-award information on 6 of 15 contract proposals was not accurate, complete, or current. In 1979, we again reported that pricing information submitted by some vendors was unreliable. Moreover, only 1 pre-award audit and 10 postaward audits had been conducted during fiscal years 1977 and 1978 of which 9 found inaccurate sales information had been reported by vendors or the availability of better discounts had not been disclosed. These problems continued throughout the 1980s. In the early 1990s, GSA made good use of pre-award and postaward audits, negotiating nearly $480 million in cost savings and recovering about $90 million in vendor overcharges over 5 years. However, in August 1997, GSA revised its acquisition regulations and effectively eliminated the use of postaward audits. While GSA expected pre-award audits to increase, this increase never materialized. In August 2001, the GSA Inspector General reported that GSA was not consistently negotiating most favored customer pricing. For just one contract, the Inspector General projected that over the contract's term, GSA customers would pay nearly $40 million more than they should have. In February 2005, we completed our most recent review of the multiple award schedules program and found that pricing problems persist and that the number of pre-award audits continued to decline. We concluded that GSA was continuing to miss opportunities to save hundreds of millions of dollars.
GAO-05-911T, Contract Management: Opportunities Continue for GSA to Improve Pricing of Multiple Award Schedules Contracts
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Testimony Before the Subcommittee on Federal Financial Management,
Government Information, and International Security, Committee on
Homeland Security and Governmental Affairs, U.S. Senate:
United States Government Accountability Office:
GAO:
For Release on Delivery Expected at 2:30 a.m. EDT:
Tuesday, July 26, 2005:
Contract Management:
Opportunities Continue for GSA to Improve Pricing of Multiple Award
Schedules Contracts:
Statement of David E. Cooper, Director:
Acquisition and Sourcing Management:
GAO-05-911T:
GAO Highlights:
Highlights of GAO-05-911T, a report to the Subcommittee on Federal
Financial Management, Government Information, and International
Security, Committee on Homeland Security and Governmental Affairs, U.S.
Senate:
Why GAO Did This Study:
Each year, federal agencies spend billions of dollars to buy commercial
products and services through the General Service Administration‘s
(GSA) Multiple Award Schedules program. The program has grown
significantly over the past several years. Currently, federal agencies
can directly purchase, through more than 16,000 schedule contracts,
over 8 million products from more than 10,000 commercial vendors. In
fiscal year 2004, purchases from these contracts totaled more than $32
billion.
The multiple award schedules program is designed to take advantage of
the government‘s significant buying power. To maximize savings, GSA
negotiates discounts that are equal to or greater than those given to
the vendor‘s most favored customers. This testimony focuses on GSA‘s
historic use of two proven negotiation tools to improve the pricing of
schedules contracts”pre-award audits and postaward audits of pre-award
information. Pre-award audits allow GSA to avoid potential overpricing
by verifying vendor pricing information before contracts are awarded.
Postaward audits allow GSA to identify overpricing of awarded contracts
and recover overcharges.
What GAO Found:
Historically, GSA has used pre-award and postaward audits sporadically,
thereby minimizing its ability to avoid excessive pricing and recover
overcharges and potentially save millions of federal dollars. For more
than 25 years, GAO has reported on GSA‘s multiple award schedules
program pricing problems. In March 1977, we reported that pre-award
information on 6 of 15 contract proposals was not accurate, complete,
or current. In 1979, we again reported that pricing information
submitted by some vendors was unreliable. Moreover, only 1 pre-award
audit and 10 postaward audits had been conducted during fiscal years
1977 and 1978 of which 9 found inaccurate sales information had been
reported by vendors or the availability of better discounts had not
been disclosed. These problems continued throughout the 1980s. In the
early 1990s, GSA made good use of pre-award and postaward audits,
negotiating nearly $480 million in cost savings and recovering about
$90 million in vendor overcharges over 5 years.
However, in August 1997, GSA revised its acquisition regulations and
effectively eliminated the use of postaward audits. While GSA expected
pre-award audits to increase, this increase never materialized. In
August 2001, the GSA Inspector General reported that GSA was not
consistently negotiating most favored customer pricing. For just one
contract, the Inspector General projected that over the contract‘s
term, GSA customers would pay nearly $40 million more than they should
have. In February 2005, we completed our most recent review of the
multiple award schedules program and found that pricing problems
persist and that the number of pre-award audits continued to decline.
We concluded that GSA was continuing to miss opportunities to save
hundreds of millions of dollars.
Pre-award Audits in Fiscal Years 1992 through 2004:
[See PDF for image]
[End of figure]
What GAO Recommends:
In its February 2005 report, GAO made three recommendations aimed at
improving the multiple award schedules contracts pricing.
www.gao.gov/cgi-bin/getrpt?GAO-05-911T.
To view the full product, including the scope and methodology, click on
the link above. For more information, contact David E. Cooper at (202)
512-4841 or cooperd@gao.gov.
[End of section]
Chairman Coburn and Members of the Subcommittee:
Thank you for inviting me here today to discuss the General Services
Administration's (GSA) use of pre-award and postaward audits in pricing
its multiple award schedules contracts. Each year, federal agencies
spend billions of dollars to buy commercial products and professional
services through GSA's multiple award schedules program. The program is
designed to take advantage of the government's significant buying power
when purchasing a wide range of commercially available products--such
as office furniture and supplies, personal computers, and tools--and a
variety of professional services. Through more than 16,000 contracts,
federal agencies can directly purchase more than 8 million products
from more than 10,000 commercial vendors. The multiple award schedules
program has grown significantly over the past several years. In fiscal
year 2004, federal agencies purchased more than $32 billion of products
and services through the program.
To get the most out of each taxpayer dollar, GSA seeks to leverage the
government's immense buying power by negotiating discounts from the
vendor's price list that are equal to or greater than the vendor's most
favored customers.[Footnote 1] These negotiations have a direct bearing
on how economically government agencies procure products and services.
Today, my statement will focus on GSA's historic use of two proven
negotiation tools to improve the pricing of schedules contracts--pre-
award audits and postaward audits of pre-award information. Pre-award
audits allow GSA contract negotiators to avoid potential vendor
overpricing by verifying pricing information before contracts are
awarded. Postaward audits allow negotiators to identify overpricing of
awarded contracts and recover overcharges.
In summary, GSA has used these two key price negotiation tools on a
limited basis. When GSA has used pre-award and postaward audits, it has
been able to avoid or recover hundreds of millions of dollars in
overcharges. In recent years, however, the use of these pricing tools
has declined dramatically--despite dramatic increases in program sales.
Consequently, GSA has less assurance that vendor-supplied pricing
information is accurate, complete, and current, and its ability to
deter overpricing and recover overcharges has been minimized. By
delaying action to address its contract pricing problems, GSA continues
to miss opportunities to minimize prices paid for goods and services
and save significant sums of federal dollars.
Background:
GSA established the Federal Supply Schedule (FSS) program in 1949 to
facilitate federal agencies' purchase of common products and services
from commercial vendors through schedule contracts. The multiple award
schedules program, the largest FSS program, was designed to provide
agencies with a simplified method for purchasing varying quantities of
a wide range of commercially available products, such as office
furniture and supplies, personal computers, scientific equipment,
network support, and various professional services.[Footnote 2] The
schedules program provides advantages to both federal agencies and
vendors. By using this simplified method of procurement, agencies can
avoid using other more time-consuming and administratively costly
procurement methods. Vendors receive wider exposure of their commercial
products and services and expend less effort to sell them.
In administering the multiple award schedules program, GSA is
responsible for ensuring that negotiated prices reflect the
government's aggregate buying power. GSA contracting officials seek
discounts from a vendor's price list that are equal to or greater than
the vendor's most favored customer's discounts. GSA awards contracts to
multiple vendors supplying comparable commercial products and services.
Federal agencies order products and services directly from the vendors
that best meet their needs. Prices paid by federal agencies include a
fee for GSA to recover program costs, including contract administration
and program support.[Footnote 3]
In the mid-1990s, GSA had about 5,200 schedules contracts. By fiscal
year 2004, this number had increased to over 16,000 contracts. As the
number of contracts offering products and services to federal agencies
increased, the sales volume skyrocketed. Between fiscal years 1995 and
2004, program sales increased more than sixfold, from $4.9 billion to
about $32.5 billion (see fig. 1).
Figure 1: Multiple Award Schedules Sales Volume and Contracts, Fiscal
Years 1995 through 2004:
[See PDF for image]
[End of figure]
Because prices that agencies pay for schedule products and services are
the result of negotiations between GSA and individual vendors, the
pricing of products and services being offered is key to the contract
negotiation process. GSA contracting officials use various tools to
analyze vendor offers and establish negotiation objectives. Tools
commonly used include market research, sales histories, invoices and
references, and competitor price lists. Of all the pricing tools
available for contract negotiation, two tools--pre-award audits and
postaward audits of pre-award information--are specifically designed to
protect the government from overpricing. Pre-award audits enable
contract negotiators to verify that vendor-supplied pricing information
is accurate, complete, and current before the contract is awarded.
Postaward audits serve as a deterrent to overpricing and a primary tool
for recovering vendor overcharges.
Historically, GSA Has Not Consistently Made Good Use of Pre-award and
Postaward Audits:
GSA's use of pre-award audits and postaward audits of pre-award
information has been sporadic--a finding we have reported for more than
25 years. For example, in March 1977, we reported that although sales
from multiple award schedules contracts amounted to $840 million,
vendor proposals were rarely independently audited and the veracity of
the information submitted was suspect.[Footnote 4] We found that sales
and discount information submitted on 6 of 15 contract proposals was
not accurate, complete, and current. Further, we found that 25 pre-
award audits done in fiscal years 1973 and 1974 had resulted in
recommendations of $962,000 in savings. Eighteen postaward audits done
in the same years resulted in GSA claims of more than $1.4 million. In
1979, we again reported that price information submitted by some
vendors was unreliable.[Footnote 5] Also, our comparison of 29 products
available through four states' annual contracts, as well as GSA
schedules, found that prices were on average 20 percent to 57 percent
lower under the state contracts. We estimated that had GSA obtained the
same discounts as did the states, $5.8 million would have been saved in
fiscal year 1978 on purchases of calculators, dictating equipment,
typewriters, and lamps from the same manufacturers. Moreover, of the 11
audits (1 pre-award and 10 postaward) that had been done during fiscal
years 1977 and 1978, all but 2 found inaccurate sales information had
been reported by vendors or the availability of better discounts had
not been disclosed.
Pricing problems continued throughout the 1980s, and GSA's use of pre-
award audits and postaward audits of pre-award information was limited.
For example, in 1986, we again reviewed GSA's price negotiations for
the multiple award schedules program, which at that time consisted of
about 3,300 contracts with sales of about $2.3 billion. Our review of
20 contracts found that while the prices GSA obtained appeared to be
fair and reasonable, action was needed to obtain better
prices.[Footnote 6] On one multiple award schedules contract, where the
vendor did not offer the government discounts comparable to the most
favored customer, a reopening of contract negotiations resulted in an
estimated savings of $1.6 million. We also found that the number of pre-
award audits decreased between fiscal years 1984 and 1985. The decrease
was attributed to reductions in the Inspector General's staff, a shift
in resources to audits of higher dollar value contracts, and the change
from single-year to multiple year contracts. In response to our concern
about the continuing decline in the number of pre-award audits, GSA
agreed to take actions to provide adequate audit coverage, including
shifting resources from other GSA offices to the Inspector General's
office, as well as within the office, and an increase in the Inspector
General's fiscal year 1987 budget.
In the early 1990s, schedules sales remained relatively stable, ranging
between $4 billion and $5 billion, annually. During this period, GSA
successfully performed a significant number of pre-award and postaward
audits. For example, from fiscal years 1992 through 1996, the GSA
Inspector General conducted 624 pre-award audits--an average of 125
each year. These pre-award audits resulted in nearly $480 million in
negotiated cost savings for GSA's customers. Additionally, from fiscal
years 1990 through fiscal year 1994, the GSA Inspector General reported
that it recovered an average of $18 million each year in vendor
overcharges. Most of these postaward audit recoveries were the result
of vendor failure to provide accurate, complete, and current
information in the negotiation of their contracts and their failure to
report and offer price reductions.
Despite Skyrocketing Sales, Pricing Problems and the Overall Decline in
the Use of Pre-award Audits Have Continued:
In August 1997, GSA revised its acquisition regulations to expand
access to commercial products and services and implement greater use of
commercial buying practices. As part of this revision, GSA specifically
removed[Footnote 7] language from the examination of records clause
that automatically granted postaward audit rights for pre-award pricing
information in every schedules contract.[Footnote 8] To offset the
reduction in these postaward audits, GSA proposed to increase emphasis
on the use of pre-award audits. According to GSA, this approach would
provide the contracting officer a mechanism for verifying information
submitted by vendors and avoid pricing problems instead of uncovering
problems after contract award. However, recent GSA Inspector General
and GAO reviews have shown that GSA's long-standing pricing problems
have continued and the plan to increase the use of pre-award audits
never materialized.
GSA's Inspector General and GAO Continue to Identify Pricing Problems:
In August 2001, the GSA Inspector General reported that while schedules
program sales had grown dramatically, certain program fundamentals--
including pricing objectives and other pricing tools--had been
marginalized.[Footnote 9] Specifically, the Inspector General found
that contracting officers were not consistently negotiating most
favored customer pricing or adequately performing price analyses. For
example, the Inspector General reported that a major distributor of
information technology products sold its top 10 GSA-selling models to
commercial customers at an average price that was 6 percent lower than
the price offered to federal agencies. The Inspector General projected
that over the contract's term, GSA customers would pay nearly $40
million more for these products than they should.
In February 2005, we completed our most recent review of the multiple
awards schedules program and found that contract pricing continues to
be a problem.[Footnote 10] Table 1 summarizes the extent of the
problems found with 62 contracts in June 2004.
Table 1: Contract Documentation Weaknesses of Schedules Contracts by
Acquisition Center:
Acquisition center: Center for Facilities Maintenance & Hardware;
Contracts reviewed: 2;
Contracts that did not meet pricing documentation requirements[A]: 2;
Contracts with inadequate price analysis: 0;
Contracts that did not fully document price negotiations: 0;
Contracts that did not identify most favored customer price: 0.
Acquisition center: General Products Acquisition Center;
Contracts reviewed: 10;
Contracts that did not meet pricing documentation requirements[A]: 5;
Contracts with inadequate price analysis: 5;
Contracts that did not fully document price negotiations: 0;
Contracts that did not identify most favored customer price: 0.
Acquisition center: Information Technology Center;
Contracts reviewed: 10;
Contracts that did not meet pricing documentation requirements[A]: 8;
Contracts with inadequate price analysis: 5;
Contracts that did not fully document price negotiations: 7;
Contracts that did not identify most favored customer price: 4.
Acquisition center: Management Services Center;
Contracts reviewed: 10;
Contracts that did not meet pricing documentation requirements[A]: 10;
Contracts with inadequate price analysis: 9;
Contracts that did not fully document price negotiations: 9;
Contracts that did not identify most favored customer price: 4.
Acquisition center: National Furniture Center;
Contracts reviewed: 10;
Contracts that did not meet pricing documentation requirements[A]: 2;
Contracts with inadequate price analysis: 1;
Contracts that did not fully document price negotiations: 2;
Contracts that did not identify most favored customer price: 1.
Acquisition center: Office Supplies & Administrative Services
Acquisition Center;
Contracts reviewed: 10;
Contracts that did not meet pricing documentation requirements[A]: 9;
Contracts with inadequate price analysis: 6;
Contracts that did not fully document price negotiations: 6;
Contracts that did not identify most favored customer price: 2.
Acquisition center: Services Acquisition Center;
Contracts reviewed: 10;
Contracts that did not meet pricing documentation requirements[A]: 1;
Contracts with inadequate price analysis: 0;
Contracts that did not fully document price negotiations: 0;
Contracts that did not identify most favored customer price: 1.
Total[B];
Contracts reviewed: 62;
Contracts that did not meet pricing documentation requirements[A]: 37;
Contracts with inadequate price analysis: 26;
Contracts that did not fully document price negotiations: 24;
Contracts that did not identify most favored customer price: 12.
Source: GAO analysis of GSA data.
[A] Contract file documentation is to clearly establish that the vendor-
supplied pricing information was accurate, complete, and current; that
the vendor information was relied upon during the negotiations;
adequate price analysis was conducted; reasonable negotiation
objectives were established; the leverage of the total government's
requirements was considered in negotiating prices; and the prices
awarded were determined fair and reasonable.
[B] Each contract could have all, some, or none of the weaknesses
listed in each of the columns.
[End of table]
We found that a GSA review of 62 contract files identified 37
contracts--nearly 60 percent--that lacked sufficient documentation to
clearly establish that the contracts were effectively negotiated.
Twenty-six of the 62 contracts--roughly 40 percent--lacked adequate
price analyses or price negotiation documentation.
Decline of Pre-award Audits Continued:
Between fiscal years 1997 and 2004, GSA completed only 155 pre-award
audits--an average of about 19 each year, compared to the average of
125 pre-award audits annually for the prior 5 years (see fig. 2).
During this same 8-year period, schedules sales increased nearly five-
fold from about $6.6 billion in fiscal year 1997 to $32.5 billion in
fiscal year 2004.
Figure 2: Pre-award Audits Conducted in Fiscal Years 1992 through 2004:
[See PDF for image]
[End of figure]
As the number of pre-award audits performed continued to decline, so
too did the amount of negotiated cost savings. Between fiscal years
1992 and 1997, the GSA Inspector General reported a total of nearly
$496 million in savings--an average of nearly $83 million per year.
Between fiscal years 1998 and 2004, the total savings reported had
dropped to about $126 million--an average of only $18 million per year
(see fig. 3).
Figure 3: Negotiated Cost Savings from Pre-award Audits Conducted in
Fiscal Years 1992 through 2004:
[See PDF for image]
[End of figure]
According to GSA Inspector General and contracting officials, the
decline in pre-award audits was largely due an organizational culture
that stresses making award decisions quickly and because pre-award
audits were not emphasized institutionally in GSA. Also, GSA management
officials told us that they believe increasing the contract length from
1 year in the mid-1990s to the 5 years of today has also limited pre-
award audits because the number of opportunities for pre-award audits
has been reduced. We believe, however, that the potential for pre-award
audits is substantial. Since the mid-1990s, the number of schedules
contracts awarded increased from about 5,200 in fiscal year 1995 to
over 16,000 in fiscal year 2004, significantly increasing the potential
for pre-award audits.
While conducting our review, we tested GSA's assertion that longer-term
contracts reduced the opportunity for pre-award audits, applying GSA's
guidance[Footnote 11] to contract negotiators on when to request audit
assistance. As we reported in February 2005, we found that 71 contracts
awarded or extended in fiscal year 2003 met the pre-award audit
threshold, but GSA only completed 14 pre-award audits--57 fewer than we
identified as potential audits. In fiscal year 2004, GSA selected 55
contract offers for pre-award audits. The GSA Inspector General
completed 40 of these audits.
In our most recent review, we also found that GSA has not conducted
postaward audits of pre-award information since 1997--when GSA revised
its policy on the use of such audits. The revised policy had the effect
of eliminating the use of postaward audits. With the dramatic increase
in sales and the continuing decline in pre-award audits, the potential
for significant recoveries of vendor overcharges could be substantial.
Recent GSA Actions to Improve Price Negotiations:
In our February 2005 report, we made three recommendations aimed at
helping GSA ensure that prices are effectively negotiated for schedules
contracts. We recommended that the GSA Administrator (1) ensure that
pre-award audits are conducted when the threshold is met for both new
contract offers and contract extensions, (2) develop guidance to help
contracting officers determine when postaward audits are needed, and
(3) direct GSA program management to revise its quality control program
to (a) determine the underlying causes for contract pricing
deficiencies and (b) develop appropriate plans to implement corrective
actions.
GSA management officials agreed with our recommendations, and stated
that GSA would:
* continue to work with the Inspector General to increase and improve
the number of pre-award audits,
* publish an advance notice of proposed rulemaking in the Federal
Register to request comments on the role of postaward audit reviews in
the acquisition process,[Footnote 12] and:
* evaluate the results of the fiscal year 2004 contract file review and
that this evaluation would involve a discussion and identification of
the underlying reasons for any weaknesses.
We believe that GSA's actions are a good first step toward addressing
its long-standing pricing problems with multiple award schedules
contracts. However, unless these actions are effectively implemented
the risk of pricing problems will continue.
In conclusion, while GSA's schedules program has provided the
government with a more flexible and cost-effective approach to buying
commercial items, our work has shown that the program has long been
fraught with problems of contract overpricing--resulting in millions of
taxpayer dollars being wasted. Historically, pre-award and postaward
audits have proven their value in deterring overpricing and recovering
vendor overcharges. Until GSA takes steps to ensure the appropriate use
of available pricing and negotiation tools, it will continue to miss
opportunities to save the government hundreds of millions of dollars in
the procurement of goods and services.
Mr. Chairman and Members of the Subcommittee, this concludes my
prepared statement. I will be happy to address any questions you may
have at this time.
Contact and Acknowledgments:
For further information, please contact David E. Cooper at (202) 512-
4841 or by e-mail at cooperd@gao.gov. Contact points for our Offices of
Congressional Relations and Public Affairs may be found on the last
page of this testimony. Individuals making key contributions to this
testimony include James Fuquay, Sanford Reigle, Victoria Klepacz, Karen
Sloan, and Sylvia Schatz.
FOOTNOTES
[1] The most favored customer is a customer or category of customers
that receives the best discounts from the vendor's commercial price
list. 48 C.F.R. 538.270(a).
[2] In 1960, GSA delegated authority to the Veterans Administration to
manage and award schedules contracts for all medical products and
services needed throughout the federal healthcare system.
[3] The GSA schedule fee in fiscal year 2005 is 0.75 percent of
negotiated item or service price. 68 Fed. Reg. 41286 (July 11, 2003).
[4] GAO, Federal Supply Service Not Buying Goods at Lowest Possible
Price, PSAD-77-69 (Washington, D.C.: Mar. 4, 1977).
[5] GAO, Ineffective Management of GSA's Multiple Award Schedule
Program--A Costly, Serious, And Longstanding Problem, PSAD-79-71
(Washington, D.C.: May 2, 1979).
[6] GAO, GSA Procurement: Are Prices Negotiated for Multiple Award
Schedules Reasonable?, GAO/GGD-86-99BR (Washington, D.C.: July. 8,
1986).
[7] The revised regulations allow the contracting officers to modify
contract language to provide for postaward access to vendor-supplied
information if they determine there was a likelihood of significant
harm to the government without such access, and obtain the senior
procurement executive's approval.
[8] GSA, however, retained the right to conduct postaward audits for
overbilling, billing errors, and compliance with the Price Reduction
and Industrial Funding Fee clauses. GSAR 552.215-71.
[9] General Services Administration, Office of Inspector General, MAS
Pricing Practices: Is FSS Observing Regulatory Provisions Regarding
Pricing? (Washington, D.C.: Aug. 24, 2001).
[10] GAO, Contract Management: Opportunities to Improve Pricing of GSA
Multiple Award Schedules Contracts, GAO-05-229 (Washington, D.C.: Feb.
11, 2005).
[11] Procurement Information Bulletin (PIB) 03-4: Audit Assistance-
Multiple Award Schedule (MAS) Contracts; General Services
Administration, June 20, 2003. This guidance instructs contract
negotiators to request audit assistance when the dollar value for
estimated sales of a contract offer or extension exceeds $25 million
for the 5-year contract period.
[12] GSA published advance notice of proposed rulemaking in the Federal
Register on March 11, 2005, requesting comments on whether postaward
audit provisions should be included in its FSS contracts and
governmentwide acquisition contracts. The Federal Register notice was
amended on March 17, 2005 (70 FR 13005) and again on April 12, 2005 (70
FR 19051) to extend the comment period until May 10, 2005, and to add
further comments concerning the Examination of Records clause at GSAR
552.215-71.
