The Bryan System^SM: Tales of Noncompliance

GSA Contractor: Major IT Company

Infraction: The GSA Contractorunderstated its discounts to commercial customers

Cost Of Infraction: $98.5 million (largest fine ever for GSA non-compliance)

A best practice included in The Bryan System^SM is a process for checking the discount on every proposal to, and award from, the Basis of Award (BOA) Customer. This process includes a checklist for comparison between the GSA price, the BOA customer price and the discount ratio negotiated at contract award. By using this process, Oracle would have been able to observe discrepancies between disclosures to GSA and actual commercial practices. By uncovering the discrepancies through the checklist process, the company could have taken immediate action to remedy the situation.

GSA Contractors: Major Office Suppliers

Infraction: Sold products that were not Trade Agreement Act (TAA) compliant

Cost Of Infraction: $27.15 million (collectively)

A best practice included in The Bryan System^SM is a process for constantly updating TAA information for each product already on the Schedule or to be added to the Schedule. This process includes a form letter of supply and a form product update letter for the manufacturer to complete and verify country of origin information for each product provided by it. By constantly updating product information as called for in Dr. Bryan's TAA process, these companies could have taken immediate action to remove the non-compliant products upon disclosure by the manufacturer.

GSA Contractor: Major Technology Advisor

Infraction: Predecessor Corporation falsely certified itself as a "small business"

Cost Of Infraction: $1 million

A best practice included in The Bryan System^SM is a process for continually verifying small business size and business designation information. This process includes a checklist for confirming the company's business size with the appropriate company officer. By constantly updating company information by using the checklist process, this company could have taken immediate action to remedy the erroneous certification.

More in The Bryan System^SM

• The Bryan System^SM
• GSA Systems Analysis^SM
• GSA Doc-It Software
• Dr. Bryan's GSA Compliance System Book
• Why Comply?
• Tales of Noncompliance

The Bryan System^SM

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