Understanding Contractor Team Arrangements (CTAs) in GSA Schedule Contracts
In the federal government contracting , various teaming arrangements exist to enable businesses to collaborate on procurement opportunities. One such arrangement specific to the General Services Administration (GSA) Schedule program is the Contractor Team Arrangement (CTA). Unlike traditional prime-subcontractor relationships or joint ventures, CTAs provide a flexible structure where two or more GSA Schedule contractors collaborate to offer a comprehensive solution to the government while maintaining their independent contractual responsibilities.
CTAs differ from other teaming mechanisms because they are not governed by the Federal Acquisition Regulation (FAR) Subpart 9.6 but are instead subject to the discretion of the ordering agency based on the solicitation. The defining feature of a CTA is that its members are considered co-prime contractors rather than a prime-subcontractor relationship. Each team member holds a GSA Schedule contract and contributes products or services under their own contract terms and pricing. This structure allows businesses to pursue opportunities that they might not be able to fulfill individually by combining their strengths and resources.
A CTA is particularly beneficial when multiple GSA Schedule contractors need to collaborate to deliver a complete solution that spans multiple Special Item Numbers (SINs) or GSA Schedule contracts. Since each team member retains privity of contract with the government, they are directly accountable for compliance with their respective GSA Schedule terms and conditions. This is in contrast to a subcontracting arrangement, where the prime contractor is solely responsible for contract performance, and the subcontractor operates under the prime’s agreement.
Another critical aspect of CTAs is the role of the lead contractor. While one contractor typically takes the lead in organizing and coordinating efforts, it does not hold a superior position over other team members. Each contractor within the CTA maintains autonomy over their pricing, invoicing, and performance obligations. However, GSA advises against structuring CTAs in a way where the lead contractor invoices the government on behalf of all team members. Instead, each team member should invoice separately to ensure transparency and compliance with GSA regulations.
Set-aside requirements also apply uniquely to CTAs. If a government solicitation is set aside for small businesses, each CTA member must independently qualify under the designated size standard. This ensures that large businesses cannot use a CTA as a means to circumvent small business participation requirements. Unlike joint ventures, CTAs do not create a new legal entity, nor do they require a separate registration in the System for Award Management (SAM). Instead, each CTA member remains individually responsible for its contractual obligations, making this structure appealing to companies that want to maintain their existing legal and financial independence while benefiting from a collaborative approach.
To effectively establish a CTA, the participating contractors must carefully define their roles and responsibilities, including project leadership, pricing structures, and work allocations. While the flexibility of CTAs provides significant advantages, improper structuring or misaligned expectations can create challenges. For this reason, businesses entering into a CTA should ensure that their agreements clearly outline task assignments, invoicing procedures, and compliance requirements to prevent disputes and operational inefficiencies.
Disclaimer: This blog post is for informational purposes only and does not constitute legal advice. While efforts have been made to ensure accuracy, the information provided is not guaranteed to be complete or up-to-date. Readers should consult with legal or contracting professionals before making decisions based on this content.
