EPA Moratorium Extension
With the ongoing inflation continuing to impact all contract holders, GSA has extended their Temporary Moratorium on Economic Price Adjustments. Previously set to expire September 30, 2022, the deadline has been moved to March 31, 2023. ** This has since been extended to December 31, 2024**
For quick reference, this memorandum will implement the following changes:
Modifications requesting an increase above the normal allowable EPA Ceiling stated in 552.216-70 for each industry, will no longer have to be approved by the contracting director, but instead to just one level above the contracting officer (It will be a bit easier to get these requests through)
Relaxes time limitations on EPA increases (Normally, vendors have to wait until your contract is 1 year old to request an EPA- but this removes that limitation.)
Relaxes limitations on the number of EPA increases a contractor may request (Typically, vendors can only request a price increase 3x a year, this removes that limitation)
If you have previously removed an item, you may add that item back at a higher price point (This is not allowed under normal circumstances)
**It is up to each reviewing Contracting Officer to determine what requests are reasonable/eligible and may negotiate, accept, or remove items at their discretion.**
If you are finding that your current offerings on GSA are not keeping pace with the current inflation rates, now is the time to submit a modification to request those increases you need to keep your contract functioning properly. You should be aware that GSA may request supporting documentation to show that you have also increased your rates to your commercial (non-GSA) customers as well. This may mean showing invoices that reflects the percent increase you are trying to get your GSA rates raised by. It is up to each CO to determine what they deem reasonable to process these requests.
If you’d like to see the updated Acquisition Letter that spells out all the details, you can find that here:
chrome-extension://efaidnbmnnnibpcajpcglclefindmkaj/https://www.gsa.gov/system/files/MV-22-02%20with%20sups%201-4.pdf?utm_medium=email&utm_source=govDelivery
As always if you have any questions at all regarding the EPA moratorium, or general management of your GSA contract, please don’t hesitate to reach out at info@elevategsa.com.