GSA Annual Reviews: What Contracting Officers Check

GSA Annual Reviews: What Contracting Officers Check

GSA contracting officers periodically review active Schedule contracts to assess compliance, performance, and contract currency. These annual reviews — formally or informally conducted — are different from audits but serve as a compliance health check for your contract. Understanding what COs look for during reviews helps you maintain a contract that will sail through review without issue.

What Annual Reviews Examine

During a contract review, the CO typically examines: your 72A sales reporting history (are reports current and payments made?), your pricelist currency (are items current, are discontinued products removed?), your Mass Modification response history (have you accepted all applicable MassMods?), your SAM.gov registration status (is it active?), and your overall compliance standing (any outstanding Show Cause or Cure notices?). Reviews may also include a check of your CPARS ratings if you have active task orders, and your subcontracting compliance if you are a large business.

Common Issues Found During Reviews

The most common issues COs find are: stale or discontinued products still listed on the Schedule pricelist (create TAA and pricing compliance exposure), unreported Mass Modifications (leaves contract in administrative limbo), and outstanding deficiency letters that were not resolved (sometimes letters are missed in email filters). Each of these is easily correctable if caught early — problematic if they accumulate over multiple review cycles.

Facts in this article verified against GSA.gov and FAI.gov as of March 2026. GSA program requirements are updated periodically — always confirm details directly with GSA or your contracting officer.