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VA Federal Supply Schedule Service

 

Contractors - Commercial Sales Practices Format

  1. What is the difference between the tracking customer and the most favored customer?
  2. Can the tracking customer be the same as the most favored customer?
  3. Are we required to disclose all commercial pricing between the most favored customer and the offered Government price?
  4. Can we identify a category of customer as our MFC?
  5. What is meant by “current” sales?
  6. Can we add line items to our contract that have little or no commercial sales?
  7. What level of detail should I provide for each column in CSP–1?
  8. Should prices to international customers be included in the MFC pricing?
  9. Should I provide the required information for each vendor on a separate worksheet within the spreadsheet?

1.  What is the difference between the tracking customer and the most favored customer?

The most favored customer is defined as the “customer or class of customer that receive(s) the best discount and/or price agreement on a given item from a supplier, regardless of terms and conditions.”  The term includes any entity that does business with your firm.  In MAS contracting, the Government’s negotiation objectives are developed based on a comparison of the MFC arrangement.  This is a required disclosure.

Established at time of contract award, the tracking customer is the customer, or category of customer against which awarded FSS pricing is tracked.  This relationship is utilized throughout the life of the contract to determine the potential for price changes.  The tracking customer must be someone that represents the Government’s discount.  The tracking customer is negotiated at time of contract award and the addition of products.  In the price reductions clause the tracking customer is referred to as the basis of award.

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2.  Can the tracking customer be the same as the most favored customer?

Yes, the tracking customer can be the same as the most favored customer if that customer or category of customs is appropriate for tracking purposes.

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3.  Are we required to disclose all commercial pricing between the most favored customer and the offered Government price?

Yes, you are required to disclose all commercial pricing that is equal to or better than the price offered to the Government.

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4.  Can we identify a category of customer as our MFC?

Yes, your MFC can be a category of custom as long as all entities within the category receive the same pricing and discounts.  If all customers within the category do not receive the same pricing/discounts, then you must identify them as individual entities.  Refer to the instructions for Figure 515.4–2 column 1 for more information.

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5.  What is meant by “current” sales?

Sales that are made during the previous 12 month time period, or the offeror’s last fiscal year are considered current for the purposes of CSP disclosures.

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6.  Can we add line items to our contract that have little or no commercial sales?

Line items can be added to a Schedule contract without consideration of a sales dollar threshold as long as the item meets the definition of a commercial item as defined by FAR 2.101.

In accordance with FAR 10.404-1(a), price analysis is the main method of determining fair and reasonable pricing for commercial items.  As such, the main analysis method our contract specialists employ when reviewing a solicitation proposal or product addition modification is to compare the pricing offered to the Government against commercial pricing disclosures.  To make this determination, your CS may ask for some or all of the following (not wholly inclusive):

  • Copies of current commercial agreements to sell the item at a contracted price (without actual sales having yet taken place);
  • Information supporting current sales to the federal Government (typically, the federal Government is not recognized as a commercial customer); or
  • If your firm is a reseller/distributor, you may be required to submit the manufacturer commercial sales practice information.

Our contract specialists are specially trained in MAS contracting policies & procedures, and we expect them to follow the price analysis techniques as outlined in FAR 15.404-1(b)(2)(3) when making a fair and reasonable pricing determination.

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7.  What level of detail should I provide for each column in CSP-1?

You are required to provide the individual discounts and other terms for each customer that receives equal to or better pricing than that offered to the Government.  This information should also be included if it varies by product line.

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8.  Should prices to international customers be included in the MFC pricing?

You are only required to disclose pricing to commercial international customers if you are opting to provide overseas delivery (see Exhibits 9 & 10 of the solicitation for more information on overseas delivery).  If you are not offering overseas delivery, then you are only required to disclose pricing offered to domestic commercial customers.

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9.  Should I provide the required information for each vendor on a separate worksheet within the spreadsheet?

Provide all information in one worksheet, with each vendor on a separate row within the sheet.

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