Digital certificates, which authorized negotiators must maintain in order to access GSA’s online contracting environment, will now also be needed to report contract sales and remit the Industrial Funding Fee (IFF) for contracts participating in the Transactional Data Reporting (TDR) pilot (see our blog for information about the current rollout schedule for this program). GSA’s Level 3 PKI digital certificates are issued by one of two approved vendors, are specific to the individual named on the certificate, and are valid for two years. Department of Defense ECA certificates also work in GSA systems.
Contractors participating in TDR will be required to report transactional sales data to GSA monthly and to remit the IFF on those sales either monthly or quarterly, as the contractor elects, through GSA’s new FAS Sales Reporting portal. Contractor points of contact authorized to report and pay IFF will be required to possess valid digital certificates in order to access this site. GSA has provided guidance and a tutorial on sales reporting for contractors who switch to TDR. However, you must have a valid digital certificate for GSA in order to access the guidance and tutorial site.
Digital certificates are still necessary to submit and sign GSA contract eOffers and eMods. If a contractor doesn’t have a valid certificate holder who is authorized to sign and commit the contractor, no contract actions requiring signature can take place. These can include needed additions to the contract, price increases, required price reductions, and other essential modifications – possibly resulting in loss of bidding and sales opportunities. Likewise, a hard-fought award or option renewal could be jeopardized without valid contractor e-signature authority.
Keep in mind that GSA contracting officers are evaluated, in part, on the speed at which they process offers and modifications. When GSA approves an action, they like the vendor to sign it promptly. We have seen GSA threaten to reject modifications if the contractor cannot sign quickly. As a best practice, verify you have at least one valid digital certificate upon receipt of your option notice. Since negotiators can only access modifications submitted after they are added to the contract, adding a new negotiator mid-stream won’t resolve this problem.
Aronson highly recommends that each contractor maintain enough certificate holders with signatory authority on the contract to ensure continuous signatory availability – don’t forget about vacations. The application process takes approximately 1-2 weeks and involves sending in a simple notarized letter and copies of required personal identification. Each certificate issued is specific to the certificate holder, but can and should be backed up to ensure the certificate is always available. We have seen more than a few certificates lost when a negotiator gets a new computer.
Not ensuring continuous coverage by certificate holders on your contract is like not having a pen available to sign offers, modifications, and now sales reporting, for those contractors switching to TDR. Obtaining a sufficient number of certificates and keeping them current is always in a contractor’s best interest.
For assistance in complying with digital certificate requirements, please contact Hope Lane at (301) 231-6266 or email@example.com.