As part of Phase II of its Goldstar Initiative, GSA will be issuing mandatory modifications to ALL Schedule Contracts on June 24th to baseline its contractors’ current terms and conditions, along with negotiated exceptions. This process will be much more onerous then a standard mandatory modification. It is extremely important to read the instructions and complete the modification carefully. All of the current contract clauses will be listed for review, and the contractor must accept each clause or take an exception. Note that contractors with approved exceptions MUST register them as part of this modification; however, this is not an opportunity to request new exceptions. All exceptions are then forwarded to the Contracting Officer for approval, as he or she has the right to re-negotiate.
Additionally, these modifications will officially incorporate eVerify into every Schedule. Contractors will have the option to select whether to incorporate the eVerify Clause (FAR 52.222-54) into their contract. By declining to include eVerify, you are stating that you believe that your products and services fall under one of the exceptions listed in FAR 22.1803 (most likely the COTS exception). You will need to file for an exception with your Contracting Officer stating your rationale. If GSA does not agree that the exception applies, they may cancel your contract. Finally, contractors must re-state their intention to participate in the American Recovery and Reinvestment Act (FAR 52.204-11).
The Goldstar II Initiative is an integral part of GSA’s push toward a totally electronic contracting environment. Don’t put your contract at risk – review all terms and conditions carefully - and, as always, contact Aronson if you have any questions!
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What We Are Writing
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- The GSA Schedule: Your Ticket to the Federal Market (May 2010)
- The New FAR Codes of Conduct and Compliance Program Provisions
- The Seven Deadly Sins (of contract compliance)