Quick guide to FASCSA implementation for GSA contractors

FASCSA orders are a type of supply chain security order governed by the Federal Acquisition Supply Chain Security Act of 2018. Learn how we implement FASCSA orders and what contractors must do to comply when submitting an offer to us.

What contractors must do

Pre-award checklist

1. Review the contract type.

   • Determine if the solicitation is for a GSA-managed governmentwide contract or a GSA-funded contract (including a GSA-funded order under a GSA-managed governmentwide contract).

2. Be informed.

   • Understand the provision at FAR 52.204-29 and the clause at FAR 52.204-30 and its Alternate I.

3. Check SAM.gov.

   • Review SAM.gov for applicable FASCSA orders before you prepare and submit offers to us. SAM.gov is the go-to tool for retrieving FASCSA orders.

4. Prepare your offer. Conduct a reasonable inquiry to ensure compliance with FASCSA representation requirements.

   • Ensure you’re not providing anything that falls under any of the three types of FASCSA orders for GSA-managed governmentwide contracts.
   • Don’t offer anything covered by a FASCSA order issued by DHS for GSA-funded contracts (or whatever additional FASCSA orders are identified if the clause at FAR 52.204-30 Alternate I is used).
   • Communicate with your proposed subcontractors (at all tiers) to ensure their compliance with applicable FASCSA order(s).

If, after conducting a reasonable inquiry, you cannot certify that you will comply with the applicable FASCSA orders, you may still submit an offer; however, you must include in your offer the information required by FAR 52.204-29, paragraph (e) .

Post-award checklist

1. Review contract terms.

   • Confirm the specific provisions and clauses applicable to your contract.

2. Regularly review and update. Check SAM.gov at least once every three months to determine if new FASCSA orders have been issued that impact your supply chain.

   • Ensure excluded sources, products, and services have not been delivered to the government or used in the performance of the contract.
   • Submit a deletion modification request to your contracting officer to remove any awarded products subject to a new FASCSA order.
   • Periodically review and update internal processes to ensure continued compliance with FASCSA regulations throughout the contract lifecycle.
   • On a regular basis, check with your subcontractors (at all tiers) to ensure their compliance with applicable FASCSA order(s).

3. Report non-compliance.

   • If you become aware of any excluded sources, products, or services delivered to the government or used in the performance of a contract, promptly report it to the contracting officer.
   • Require your subcontractors (at all tiers) to do the same. We recommend creating a plan to streamline communication with your subcontractors on a regular basis to ensure compliance with the FASCSA rule.

How to check SAM.gov for FASCSA exclusion orders

Visit SAM.gov and navigate to the FASCSA order link on the homepage.

A FASCSA order broadly refers to either a FASCSA exclusion or a FASCSA removal order. The “Additional Information” field will identify if the order is an exclusion or removal order (or both).

Optional: You can automate FASCSA checks using SAM.gov’s application programming interface, also known as an API, on OpenGSA.gov for Entity and Exclusion Alerts.

Contract types

GSA-managed governmentwide contracts

We use the provision at FAR 52.204-29 and the clause at FAR 52.204-30 Alternate I for GSA-managed governmentwide contracts. We apply all three types of FASCSA orders at the basic contract level of our governmentwide contracts:

GSA-funded contracts

When we want our contractors to comply with DHS FASCSA orders only, we use the provision at FAR 52.204-29 and the clause at FAR 52.204-30.

When we want our contractors to comply with additional FASCSA orders, we use the provision at FAR 52.20-29 and the clause at FAR 52.204-30 Alternate I, selecting the applicable FASCSA orders (always including DHS FASCSA orders) by completing FAR 52.204-30 Alternate I, paragraph (b)(1):

Need help?

• For questions related to FASCSA orders, contact your contracting officer.
• For SAM.gov inquiries, contact the Federal Service Desk. Please note that FSD can only answer questions about SAM.gov and how the system works.
• Follow the initial troubleshooting instructions listed on OpenGSA for help utilizing the SAM.gov API for automatic FASCSA checks.