How to Prepare for a GSA Contract Audit
GSA conducts contract audits to verify that Schedule contractors are complying with their contract obligations — pricing accuracy, 72A reporting, IFF payment, Price Reduction Clause compliance, and TAA documentation. An audit can be triggered by routine review cycles, a tip or complaint, or unusual pricing patterns identified in Schedule data. Being audited is not automatically a negative sign — it's part of the program's integrity structure — but being unprepared for an audit can turn a routine review into a serious compliance issue.
What GSA Auditors Examine
GSA auditors (or Inspector General auditors for more significant investigations) typically review: commercial invoices to customers to verify CSP/Price Reduction compliance, 72A sales reports compared to actual order data, IFF payment records, contract modifications and pricelist history, TAA documentation for product vendors, and subcontracting compliance records for large businesses. The audit may be conducted remotely (document request by email) or on-site at your facility.
Document Retention Requirements
Maintain the following records for the duration of your contract plus at least three years after contract expiration (some records require longer retention): all commercial pricing records and invoices, CSP disclosures and supporting documentation, 72A sales reports and payment confirmations, all eMod submissions and CO approvals, task order documentation for orders performed under the Schedule, and any Price Reduction Clause notification correspondence. Organize records by contract year and maintain backup copies.
| Document Type | Minimum Retention |
|---|---|
| Commercial invoices/pricing | Contract period + 3 years |
| 72A reports and IFF payments | Contract period + 3 years |
| TAA documentation (products) | Contract period + 3 years |
| Subcontracting records | Contract period + 3 years |
Responding to an Audit Request
When notified of an audit, respond to the audit request promptly and professionally. Request clarification on the scope of the audit and the specific documentation requested. Assign one internal point of contact to coordinate document production. Produce requested documents in a well-organized manner — auditors view disorganized, incomplete, or late responses negatively. If you identify potential compliance issues during your audit preparation (pricing errors, missed PRC notifications, unreported sales), consult with your attorney or GSA compliance specialist before responding.