Testimony Before the Subcommittee on 

Federal Financial Management, Government 

Information, and International Security, 

Committee on Homeland Security and 

Governmental Affairs, U.S. Senate 

United States Government Accountability Office

GAO

For Release on Delivery 

Expected at 2:30 a.m. EDT 

Tuesday, July 26, 2005 CONTRACT 

MANAGEMENT 

Opportunities Continue for 

GSA to Improve Pricing of 

Multiple Award Schedules 

Contracts 

Statement of David E. Cooper, Director 

Acquisition and Sourcing Management 

GAO-05-911T 
What GAO Found

United States Government Accountability Office

Why GAO Did This Study

Highlights

Accountability Integrity Reliability

www.gao.gov/cgi-bin/getrpt?GAO-05-911T.

To view the full product, including the scope 

and methodology, click on the link above. 

For more information, contact David E. 

Cooper at (202) 512-4841 or 

cooperd@gao.gov. 

Highlights of GAO-05-911T, a report to the 

Subcommittee on Federal Financial 

Management, Government Information, 

and International Security, Committee on 

Homeland Security and Governmental 

Affairs, U.S. Senate 

July 26, 2005

CONTRACT MANAGEMENT 

Opportunities Continue for GSA to 

Improve Pricing of Multiple Award 

Schedules Contracts 

Historically, GSA has used pre-award and postaward audits sporadically, 

thereby minimizing its ability to avoid excessive pricing and recover 

overcharges and potentially save millions of federal dollars. For more than 

25 years, GAO has reported on GSA’s multiple award schedules program 

pricing problems. In March 1977, we reported that pre-award information on 

6 of 15 contract proposals was not accurate, complete, or current. In 1979, 

we again reported that pricing information submitted by some vendors was 

unreliable. Moreover, only 1 pre-award audit and 10 postaward audits had 

been conducted during fiscal years 1977 and 1978 of which 9 found 

inaccurate sales information had been reported by vendors or the availability 

of better discounts had not been disclosed. These problems continued 

throughout the 1980s. In the early 1990s, GSA made good use of pre-award 

and postaward audits, negotiating nearly $480 million in cost savings and 

recovering about $90 million in vendor overcharges over 5 years. 

However, in August 1997, GSA revised its acquisition regulations and 

effectively eliminated the use of postaward audits. While GSA expected preaward audits to increase, this increase never materialized. In August 2001, 

the GSA Inspector General reported that GSA was not consistently 

negotiating most favored customer pricing. For just one contract, the 

Inspector General projected that over the contract’s term, GSA customers 

would pay nearly $40 million more than they should have. In February 2005, 

we completed our most recent review of the multiple award schedules 

program and found that pricing problems persist and that the number of preaward audits continued to decline. We concluded that GSA was continuing 

to miss opportunities to save hundreds of millions of dollars. 

Pre-award Audits in Fiscal Years 1992 through 2004 

0

30

60

90

120

150

180

1992 1993 1994 1995 1996 1997 1998 1999 2000 2001 2002 2003 2004

Number of pre-award audits

130 120

126

154

94

8 21 24 24 13 11 14

40

Source: GSA Inspector General data.

0

50

100

150

200

1992 1993 1994 1995 1996 1997 1998 1999 2000 2001 2002 2003 2004

Savings (in millions of dollars)

Fiscal year

Fiscal year

60.4

167.1

38.3

38.5

174.7

17.3 8.3 18.8

57.9

1.7 28.1 4.1 6.9

Each year, federal agencies spend 

billions of dollars to buy 

commercial products and services 

through the General Service 

Administration’s (GSA) Multiple 

Award Schedules program. The 

program has grown significantly 

over the past several years. 

Currently, federal agencies can 

directly purchase, through more 

than 16,000 schedule contracts, 

over 8 million products from more 

than 10,000 commercial vendors. In 

fiscal year 2004, purchases from 

these contracts totaled more than 

$32 billion. 

The multiple award schedules 

program is designed to take 

advantage of the government’s 

significant buying power. To 

maximize savings, GSA negotiates 

discounts that are equal to or 

greater than those given to the 

vendor’s most favored customers. 

This testimony focuses on GSA’s 

historic use of two proven 

negotiation tools to improve the 

pricing of schedules contracts—

pre-award audits and postaward 

audits of pre-award information. 

Pre-award audits allow GSA to 

avoid potential overpricing by 

verifying vendor pricing 

information before contracts are 

awarded. Postaward audits allow 

GSA to identify overpricing of 

awarded contracts and recover 

overcharges. 

What GAO Recommends

In its February 2005 report, GAO 

made three recommendations 

aimed at improving the multiple 

award schedules contracts pricing. 
Page 1 GAO-05-911T 

Chairman Coburn and Members of the Subcommittee: 

Thank you for inviting me here today to discuss the General Services 

Administration’s (GSA) use of pre-award and postaward audits in pricing 

its multiple award schedules contracts. Each year, federal agencies spend 

billions of dollars to buy commercial products and professional services 

through GSA’s multiple award schedules program. The program is 

designed to take advantage of the government’s significant buying power 

when purchasing a wide range of commercially available products—such 

as office furniture and supplies, personal computers, and tools—and a 

variety of professional services. Through more than 16,000 contracts, 

federal agencies can directly purchase more than 8 million products from 

more than 10,000 commercial vendors. The multiple award schedules 

program has grown significantly over the past several years. In fiscal year 

2004, federal agencies purchased more than $32 billion of products and 

services through the program. 

To get the most out of each taxpayer dollar, GSA seeks to leverage the 

government’s immense buying power by negotiating discounts from the 

vendor’s price list that are equal to or greater than the vendor’s most 

favored customers.1

 These negotiations have a direct bearing on how 

economically government agencies procure products and services. Today, 

my statement will focus on GSA’s historic use of two proven negotiation 

tools to improve the pricing of schedules contracts—pre-award audits and 

postaward audits of pre-award information. Pre-award audits allow GSA 

contract negotiators to avoid potential vendor overpricing by verifying 

pricing information before contracts are awarded. Postaward audits allow 

negotiators to identify overpricing of awarded contracts and recover 

overcharges. 

In summary, GSA has used these two key price negotiation tools on a 

limited basis. When GSA has used pre-award and postaward audits, it has 

been able to avoid or recover hundreds of millions of dollars in 

overcharges. In recent years, however, the use of these pricing tools has 

declined dramatically—despite dramatic increases in program sales. 

Consequently, GSA has less assurance that vendor-supplied pricing 

information is accurate, complete, and current, and its ability to deter 

overpricing and recover overcharges has been minimized. By delaying 

 1

The most favored customer is a customer or category of customers that receives the best 

discounts from the vendor’s commercial price list. 48 C.F.R. 538.270(a). 
Page 2 GAO-05-911T 

action to address its contract pricing problems, GSA continues to miss 

opportunities to minimize prices paid for goods and services and save 

significant sums of federal dollars. 

GSA established the Federal Supply Schedule (FSS) program in 1949 to 

facilitate federal agencies’ purchase of common products and services 

from commercial vendors through schedule contracts. The multiple award 

schedules program, the largest FSS program, was designed to provide 

agencies with a simplified method for purchasing varying quantities of a 

wide range of commercially available products, such as office furniture 

and supplies, personal computers, scientific equipment, network support, 

and various professional services.2

 The schedules program provides 

advantages to both federal agencies and vendors. By using this simplified 

method of procurement, agencies can avoid using other more timeconsuming and administratively costly procurement methods. Vendors 

receive wider exposure of their commercial products and services and 

expend less effort to sell them. 

In administering the multiple award schedules program, GSA is 

responsible for ensuring that negotiated prices reflect the government’s 

aggregate buying power. GSA contracting officials seek discounts from a 

vendor’s price list that are equal to or greater than the vendor’s most 

favored customer’s discounts. GSA awards contracts to multiple vendors 

supplying comparable commercial products and services. Federal 

agencies order products and services directly from the vendors that best 

meet their needs. Prices paid by federal agencies include a fee for GSA to 

recover program costs, including contract administration and program 

support.3

In the mid-1990s, GSA had about 5,200 schedules contracts. By fiscal year 

2004, this number had increased to over 16,000 contracts. As the number 

of contracts offering products and services to federal agencies increased, 

the sales volume skyrocketed. Between fiscal years 1995 and 2004, 

 2

In 1960, GSA delegated authority to the Veterans Administration to manage and award 

schedules contracts for all medical products and services needed throughout the federal 

healthcare system. 

3

The GSA schedule fee in fiscal year 2005 is 0.75 percent of negotiated item or service price. 

68 Fed. Reg. 41286 (July 11, 2003). 

Background 
Page 3 GAO-05-911T 

program sales increased more than sixfold, from $4.9 billion to about $32.5 

billion (see fig. 1). 

Figure 1: Multiple Award Schedules Sales Volume and Contracts, Fiscal Years 1995 

through 2004 

Because prices that agencies pay for schedule products and services are 

the result of negotiations between GSA and individual vendors, the pricing 

of products and services being offered is key to the contract negotiation 

process. GSA contracting officials use various tools to analyze vendor 

offers and establish negotiation objectives. Tools commonly used include 

market research, sales histories, invoices and references, and competitor 

price lists. Of all the pricing tools available for contract negotiation, two 

tools—pre-award audits and postaward audits of pre-award information—

are specifically designed to protect the government from overpricing. Preaward audits enable contract negotiators to verify that vendor-supplied 

pricing information is accurate, complete, and current before the contract 

is awarded. Postaward audits serve as a deterrent to overpricing and a 

primary tool for recovering vendor overcharges. 

0

5

10

15

20

25

30

35

0

2

4

6

8

10

12

14

16

18

Sales (in billions) Number of contracts (thousands)

Source: GAO analysis of GSA data.

Sales

Number of contracts

1995 1996 1997 1998 1999 2000 2001 2002 2003 2004
Page 4 GAO-05-911T 

GSA’s use of pre-award audits and postaward audits of pre-award 

information has been sporadic—a finding we have reported for more than 

25 years. For example, in March 1977, we reported that although sales 

from multiple award schedules contracts amounted to $840 million, 

vendor proposals were rarely independently audited and the veracity of 

the information submitted was suspect.4 We found that sales and discount 

information submitted on 6 of 15 contract proposals was not accurate, 

complete, and current. Further, we found that 25 pre-award audits done in 

fiscal years 1973 and 1974 had resulted in recommendations of $962,000 in 

savings. Eighteen postaward audits done in the same years resulted in GSA 

claims of more than $1.4 million. In 1979, we again reported that price 

information submitted by some vendors was unreliable.5

 Also, our 

comparison of 29 products available through four states’ annual contracts, 

as well as GSA schedules, found that prices were on average 20 percent to 

57 percent lower under the state contracts. We estimated that had GSA 

obtained the same discounts as did the states, $5.8 million would have 

been saved in fiscal year 1978 on purchases of calculators, dictating 

equipment, typewriters, and lamps from the same manufacturers. 

Moreover, of the 11 audits (1 pre-award and 10 postaward) that had been 

done during fiscal years 1977 and 1978, all but 2 found inaccurate sales 

information had been reported by vendors or the availability of better 

discounts had not been disclosed. 

Pricing problems continued throughout the 1980s, and GSA’s use of preaward audits and postaward audits of pre-award information was limited. 

For example, in 1986, we again reviewed GSA’s price negotiations for the 

multiple award schedules program, which at that time consisted of about 

3,300 contracts with sales of about $2.3 billion. Our review of 20 contracts 

found that while the prices GSA obtained appeared to be fair and 

reasonable, action was needed to obtain better prices.6

 On one multiple 

award schedules contract, where the vendor did not offer the government 

discounts comparable to the most favored customer, a reopening of 

contract negotiations resulted in an estimated savings of $1.6 million. We 

also found that the number of pre-award audits decreased between fiscal 

 4

GAO, Federal Supply Service Not Buying Goods at Lowest Possible Price, PSAD-77-69

(Washington, D.C.: Mar. 4, 1977). 

5

GAO, Ineffective Management of GSA’s Multiple Award Schedule Program—A Costly, 

Serious, And Longstanding Problem, PSAD-79-71 (Washington, D.C.: May 2, 1979). 

6

GAO, GSA Procurement: Are Prices Negotiated for Multiple Award Schedules 

Reasonable?, GAO/GGD-86-99BR (Washington, D.C.: July. 8, 1986). 

Historically, GSA Has 

Not Consistently 

Made Good Use of 

Pre-award and 

Postaward Audits 
Page 5 GAO-05-911T 

years 1984 and 1985. The decrease was attributed to reductions in the 

Inspector General’s staff, a shift in resources to audits of higher dollar 

value contracts, and the change from single-year to multiple year 

contracts. In response to our concern about the continuing decline in the 

number of pre-award audits, GSA agreed to take actions to provide 

adequate audit coverage, including shifting resources from other GSA 

offices to the Inspector General’s office, as well as within the office, and 

an increase in the Inspector General’s fiscal year 1987 budget. 

In the early 1990s, schedules sales remained relatively stable, ranging 

between $4 billion and $5 billion, annually. During this period, GSA 

successfully performed a significant number of pre-award and postaward 

audits. For example, from fiscal years 1992 through 1996, the GSA 

Inspector General conducted 624 pre-award audits—an average of 125 

each year. These pre-award audits resulted in nearly $480 million in 

negotiated cost savings for GSA’s customers. Additionally, from fiscal 

years 1990 through fiscal year 1994, the GSA Inspector General reported 

that it recovered an average of $18 million each year in vendor 

overcharges. Most of these postaward audit recoveries were the result of 

vendor failure to provide accurate, complete, and current information in 

the negotiation of their contracts and their failure to report and offer price 

reductions. 
Page 6 GAO-05-911T 

In August 1997, GSA revised its acquisition regulations to expand access to 

commercial products and services and implement greater use of 

commercial buying practices. As part of this revision, GSA specifically 

removed7

 language from the examination of records clause that 

automatically granted postaward audit rights for pre-award pricing 

information in every schedules contract.8

 To offset the reduction in these 

postaward audits, GSA proposed to increase emphasis on the use of preaward audits. According to GSA, this approach would provide the 

contracting officer a mechanism for verifying information submitted by 

vendors and avoid pricing problems instead of uncovering problems after 

contract award. However, recent GSA Inspector General and GAO reviews 

have shown that GSA’s long-standing pricing problems have continued and 

the plan to increase the use of pre-award audits never materialized. 

In August 2001, the GSA Inspector General reported that while schedules 

program sales had grown dramatically, certain program fundamentals—

including pricing objectives and other pricing tools—had been 

marginalized.9

 Specifically, the Inspector General found that contracting 

officers were not consistently negotiating most favored customer pricing 

or adequately performing price analyses. For example, the Inspector 

General reported that a major distributor of information technology 

products sold its top 10 GSA-selling models to commercial customers at an 

average price that was 6 percent lower than the price offered to federal 

agencies. The Inspector General projected that over the contract’s term, 

GSA customers would pay nearly $40 million more for these products than 

they should. 

In February 2005, we completed our most recent review of the multiple 

awards schedules program and found that contract pricing continues to be 

 7

The revised regulations allow the contracting officers to modify contract language to 

provide for postaward access to vendor-supplied information if they determine there was a 

likelihood of significant harm to the government without such access, and obtain the senior 

procurement executive’s approval. 

8

GSA, however, retained the right to conduct postaward audits for overbilling, billing 

errors, and compliance with the Price Reduction and Industrial Funding Fee clauses. 

GSAR 552.215-71. 

9

General Services Administration, Office of Inspector General, MAS Pricing Practices: Is 

FSS Observing Regulatory Provisions Regarding Pricing? (Washington, D.C.: Aug. 24, 

2001). 

Despite Skyrocketing 

Sales, Pricing 

Problems and the 

Overall Decline in the 

Use of Pre-award 

Audits Have 

Continued 

GSA’s Inspector General 

and GAO Continue to 

Identify Pricing Problems 
Page 7 GAO-05-911T 

a problem.10 Table 1 summarizes the extent of the problems found with 62 

contracts in June 2004. 

Table 1: Contract Documentation Weaknesses of Schedules Contracts by Acquisition Center 

Acquisition center 

Contracts 

reviewed 

Contracts that did 

not meet pricing 

documentation 

requirementsa

Contracts with 

inadequate price 

analysis 

Contracts that did 

not fully document 

price negotiations 

Contracts that did not 

identify most favored 

customer price 

Center for Facilities 

Maintenance & 

Hardware 2 2 0 0 0

General Products 

Acquisition Center 10 5 5 0 0

Information Technology 

Center 10 8 5 7 4

Management Services 

Center 10 10 9 9 4

National Furniture 

Center 10 2 1 2 1

Office Supplies & 

Administrative Services 

Acquisition Center 10 9 6 6 2

Services Acquisition 

Center 10 1 0 0 1

Totalb 62 37 26 24 12

Source: GAO analysis of GSA data. 

a

Contract file documentation is to clearly establish that the vendor-supplied pricing information was 

accurate, complete, and current; that the vendor information was relied upon during the negotiations; 

adequate price analysis was conducted; reasonable negotiation objectives were established; the 

leverage of the total government’s requirements was considered in negotiating prices; and the prices 

awarded were determined fair and reasonable. 

b

Each contract could have all, some, or none of the weaknesses listed in each of the columns. 

We found that a GSA review of 62 contract files identified 37 contracts—

nearly 60 percent—that lacked sufficient documentation to clearly 

establish that the contracts were effectively negotiated. Twenty-six of the 

62 contracts—roughly 40 percent—lacked adequate price analyses or 

price negotiation documentation. 

 10GAO, Contract Management: Opportunities to Improve Pricing of GSA Multiple Award 

Schedules Contracts, GAO-05-229 (Washington, D.C.: Feb. 11, 2005). 
Page 8 GAO-05-911T 

Between fiscal years 1997 and 2004, GSA completed only 155 pre-award 

audits—an average of about 19 each year, compared to the average of 125 

pre-award audits annually for the prior 5 years (see fig. 2). During this 

same 8-year period, schedules sales increased nearly five-fold from about 

$6.6 billion in fiscal year 1997 to $32.5 billion in fiscal year 2004. 

Figure 2: Pre-award Audits Conducted in Fiscal Years 1992 through 2004 

As the number of pre-award audits performed continued to decline, so too 

did the amount of negotiated cost savings. Between fiscal years 1992 and 

1997, the GSA Inspector General reported a total of nearly $496 million in 

savings—an average of nearly $83 million per year. Between fiscal years 

1998 and 2004, the total savings reported had dropped to about $126 

million—an average of only $18 million per year (see fig. 3). 

Decline of Pre-award 

Audits Continued 

Source: GSA Inspector General data.

0

20

40

60

80

100

120

140

160

180

200

1992 1993 1994 1995 1996 1997 1998 1999 2000 2001 2002 2003 2004

Number of pre-award audits

Fiscal year

130 120

126

154

94

8

21 24 24

13 11

14

40
Page 9 GAO-05-911T 

Figure 3: Negotiated Cost Savings from Pre-award Audits Conducted in Fiscal 

Years 1992 through 2004 

According to GSA Inspector General and contracting officials, the decline 

in pre-award audits was largely due an organizational culture that stresses 

making award decisions quickly and because pre-award audits were not 

emphasized institutionally in GSA. Also, GSA management officials told us 

that they believe increasing the contract length from 1 year in the mid1990s to the 5 years of today has also limited pre-award audits because the 

number of opportunities for pre-award audits has been reduced. We 

believe, however, that the potential for pre-award audits is substantial. 

Since the mid-1990s, the number of schedules contracts awarded 

increased from about 5,200 in fiscal year 1995 to over 16,000 in fiscal year 

2004, significantly increasing the potential for pre-award audits. 

While conducting our review, we tested GSA’s assertion that longer-term 

contracts reduced the opportunity for pre-award audits, applying GSA’s 

guidance11 to contract negotiators on when to request audit assistance. As 

we reported in February 2005, we found that 71 contracts awarded or 

extended in fiscal year 2003 met the pre-award audit threshold, but GSA 

 11Procurement Information Bulletin (PIB) 03-4: Audit Assistance–Multiple Award Schedule 

(MAS) Contracts; General Services Administration, June 20, 2003. This guidance instructs 

contract negotiators to request audit assistance when the dollar value for estimated sales of 

a contract offer or extension exceeds $25 million for the 5-year contract period. 

Source: GSA Inspector General data.

0

20

40

60

80

100

120

140

160

180

200

1992 1993 1994 1995 1996 1997 1998 1999 2000 2001 2002 2003 2004

Savings (in millions of dollars)

Fiscal year

60.4

167.1

38.3 38.5

174.7

17.3 8.3

18.8

57.9

1.7

28.1

4.1 6.9
Page 10 GAO-05-911T 

only completed 14 pre-award audits—57 fewer than we identified as 

potential audits. In fiscal year 2004, GSA selected 55 contract offers for 

pre-award audits. The GSA Inspector General completed 40 of these 

audits. 

In our most recent review, we also found that GSA has not conducted 

postaward audits of pre-award information since 1997—when GSA revised 

its policy on the use of such audits. The revised policy had the effect of 

eliminating the use of postaward audits. With the dramatic increase in 

sales and the continuing decline in pre-award audits, the potential for 

significant recoveries of vendor overcharges could be substantial. 

In our February 2005 report, we made three recommendations aimed at 

helping GSA ensure that prices are effectively negotiated for schedules 

contracts. We recommended that the GSA Administrator (1) ensure that 

pre-award audits are conducted when the threshold is met for both new 

contract offers and contract extensions, (2) develop guidance to help 

contracting officers determine when postaward audits are needed, and 

(3) direct GSA program management to revise its quality control program 

to (a) determine the underlying causes for contract pricing deficiencies 

and (b) develop appropriate plans to implement corrective actions. 

GSA management officials agreed with our recommendations, and stated 

that GSA would 

• continue to work with the Inspector General to increase and improve the 

number of pre-award audits, 

• publish an advance notice of proposed rulemaking in the Federal Register 

to request comments on the role of postaward audit reviews in the 

acquisition process,12 and 

• evaluate the results of the fiscal year 2004 contract file review and that this 

evaluation would involve a discussion and identification of the underlying 

reasons for any weaknesses. 

 12GSA published advance notice of proposed rulemaking in the Federal Register on March 

11, 2005, requesting comments on whether postaward audit provisions should be included 

in its FSS contracts and governmentwide acquisition contracts. The Federal Register 

notice was amended on March 17, 2005 (70 FR 13005) and again on April 12, 2005 (70 FR 

19051) to extend the comment period until May 10, 2005, and to add further comments 

concerning the Examination of Records clause at GSAR 552.215-71. 

Recent GSA Actions to 

Improve Price 

Negotiations 
Page 11 GAO-05-911T 

We believe that GSA’s actions are a good first step toward addressing its 

long-standing pricing problems with multiple award schedules contracts. 

However, unless these actions are effectively implemented the risk of 

pricing problems will continue. 

In conclusion, while GSA’s schedules program has provided the 

government with a more flexible and cost-effective approach to buying 

commercial items, our work has shown that the program has long been 

fraught with problems of contract overpricing—resulting in millions of 

taxpayer dollars being wasted. Historically, pre-award and postaward 

audits have proven their value in deterring overpricing and recovering 

vendor overcharges. Until GSA takes steps to ensure the appropriate use 

of available pricing and negotiation tools, it will continue to miss 

opportunities to save the government hundreds of millions of dollars in the 

procurement of goods and services. 

Mr. Chairman and Members of the Subcommittee, this concludes my 

prepared statement. I will be happy to address any questions you may have 

at this time. 

For further information, please contact David E. Cooper at (202) 512-4841 

or by e-mail at cooperd@gao.gov. Contact points for our Offices of 

Congressional Relations and Public Affairs may be found on the last page 

of this testimony. Individuals making key contributions to this testimony 

include James Fuquay, Sanford Reigle, Victoria Klepacz, Karen Sloan, and 

Sylvia Schatz. 

Contact and 

Acknowledgments 

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