Navigating the Evolving GSA Landscape with Chris Arndt

Welcome to Catalyst Conversations! In our latest session, Michelle Warren sat down with Chris Arndt of the Gormley Group to unpack the whirlwind of changes hitting GSA contractors today. From the permanent removal of EPA price caps to the encroaching cybersecurity requirements of CMMC, the discussion provided a roadmap for contractors trying to maintain compliance in a shifting market. Chris, a veteran in GSA contract management, noted that while some changes offer relief, others introduce new administrative hurdles.

The End of the 10% EPA Cap

The most significant relief for contractors has been the permanent update to Economic Price Adjustment (EPA) rules. Chris explained that the 10% cap on price increases and the limits on how often you can request them are officially things of the past.

• "There is no longer a 10% cap. There is no longer a limit on the frequency. Those are the rules now. And that was made permanent, too," Chris stated.

• However, GSA has introduced a procedural twist. Despite the mass modification for Refresh 29, about a change in the EPA clause (which does not affect contracts based on commercial price lists), GSA is now requiring a separate "change of terms" modification.

• Chris described this as "a pretty cumbersome modification" and noted: "GSA put through a new EPA clause in the Refresh which everyone had to accept with the Mass Mod... Nevertheless, GSA insists on a separate mod to your contract and has required additional steps which may include a Final Proposal Revision. This is very burdensome."

The Rising Tide of Spending Thresholds

The conversation also covered the shifting dollar thresholds that dictate how the government buys.

• Micro-purchase Threshold (MPT): The MPT increased from $10,000 to $15,000 in October. Michelle Warren noted the strategic weight of this shift: "If that goes up to $100,000, it changes the whole way you approach GSA".

• Simplified Acquisition Threshold (SAT): The SAT has also jumped from $250,000 to $350,000.

• For buys within the SAT, Chris noted that Contracting Officers (COs) can streamline the process: "They just really have to go to the schedules and do a comparison... They can just go through, see who's there, do a comparison, and put it out, or make the buy".

Cybersecurity and the CMMC Threat

A major “heads up” for the furniture and interior industry is the arrival of the Cybersecurity Maturity Model Certification (CMMC). While many view this as an IT issue, Chris warned that floor plans and space plans are often classified as Controlled Unclassified Information (CUI).

• "Watch for anything in the RFQ where it says that this is considered controlled unclassified information level 2 certifications required," Chris cautioned.

• Michelle added that these requirements create a hard barrier for entry: "if you’re not CMMC certified, you’re not going to be able to go after it".

4. Tariffs and the Commercial Price List Requirement

When it comes to the "insanity" of tariffs, Chris was clear: you cannot simply add a surcharge to a GSA order. Relief must come through the commercial market first with new commercial price lists (or a sticker noting the increase commercially).

• "No, keep your helmet on. This insanity's gonna continue for quite a while," Chris noted regarding the tariff environment.

• He explained that "you cannot go out for a special surcharge on your government orders because of the tariff".

• Instead, contractors must update their commercial prices first and provide a new commercial price list to GSA to support an EPA.

Conclusion and Next Steps

The GSA landscape is more dynamic than ever, requiring contractors to be both proactive and patient. We want to thank Chris Arndt for sharing his deep expertise and helping our community stay ahead of these complex regulatory shifts.

If you are interested in elevating your public sector strategy and navigating these "cumbersome" modifications, consider joining our monthly subscription program, the Public Sector Accelerator. Our next Catalyst Conversations call will continue to dive into the practical realities of Public Sector contracting. We hope to see you there!