A publicly traded, multinational information technology consulting and software development company sought assistance with a General Services Administration (GSA) Office of Inspector General (OIG) Mandatory Disclosure related to pricing compliance with four Federal Supply Schedule (FSS) contracts.
The contracts were inherited following the acquisition of a separate legal business entity. During post-closing diligence and integration activities, potential pricing compliance issues were uncovered requiring notice to the federal government and a financial exposure analysis.
The task order population of the four FSS contracts—which were potentially impacted by the pricing non-compliance—was large and the supporting documentation was complex and disorganized. Additionally, the client had a complex business and a wide range of service offerings that required complex labor category mappings to facilitate an efficient analysis.
The client retained Baker Tilly to work collaboratively with outside legal counsel to develop a Mandatory Disclosure strategy and perform analyses to quantify contract overbilling. Baker Tilly overcame significant data challenges due to transactional sales data residing on legacy accounting systems from the acquired firm.
Utilizing Microsoft SQL Server, Baker Tilly analyzed transactional sales data for a six-year period of review, which was plagued with many inherent limitations including inconsistencies in certain data elements.
Baker Tilly also reconstructed the client’s commercial and FSS pricelists over the period of review and developed an assumption-based financial model to quantify the company’s exposure due to overbilling.
In support of outside and inside legal counsel, Baker Tilly assisted all communications between the company and OIG, including answering questions from the OIG relating to the contracts, the data and the company’s sales practices.
Baker Tilly calculated a financial impact from Price Reductions Clause (PRC) violations and overbilling, and a settlement was reached between the client and GSA OIG.
