Common GSA Compliance Violations and How to Fix Them
Most GSA compliance violations fall into a small number of recurring categories. They are rarely the result of intentional misconduct — they typically stem from inadequate processes, missed deadlines, or misunderstanding of ongoing obligations. Understanding the most common violation types and how to correct them before a CO identifies them is the essence of proactive contract compliance management.
The Five Most Common Compliance Violations
1. Missed 72A Reports: Failing to submit quarterly sales reports and IFF payments. Fix: submit all outstanding reports immediately, pay all IFF owed plus any applicable interest, and explain the cause in a written communication to your CO. 2. Price Reduction Clause Violations: Failing to notify GSA within 15 days of offering better pricing to your BOA customer. Fix: conduct an immediate review of your commercial pricing history post-award, notify the CO of any unreported reductions, and propose a retroactive remedy for the affected period. 3. TAA Non-Compliance: Selling products of non-designated country origin on your Schedule. Fix: audit your current catalog for TAA compliance, remove non-compliant items immediately via eMod, and evaluate whether a refund or credit is owed for past non-compliant orders.
4. Lapsed SAM.gov Registration: Failing to renew annual SAM.gov registration. Fix: renew immediately at sam.gov, notify your CO once active, and in the future set 60-day calendar reminders before expiration. 5. Unauthorized Price Increases: Raising Schedule prices without CO approval. Fix: submit a modification to return prices to approved levels, and prospectively request CO approval for any future increases with supporting documentation.