We would like to think that (a) (3) does, and that this would be a sale conducted by a separate contracting authority under Part 15. But I have read that the GSA is interpreting any sales to other agencies using their rates as sales under the GSA contract, because the GSA is tired of other agencies skirting the fee but taking advantage of the rates they negotiated. A prominent government accounting firm has noted that when non-GSA federal agencies align their rates to the GSA schedule, "then GSA considers that a Schedule sale even if the agency does not. GSA takes the stance that the buying agency is benefiting from all of their hard work in determining that your prices are “fair and reasonable,” so GSA deserves the IFF on that sale. GSA often says that if you reference your Schedule in your bid or just about anywhere else in a document that goes to the government customer, then you have made it a Schedule buy. So, unless you can prove to GSA that the Buying Agency did their own full pricing research, GSA will say you need to include that sale in your Schedule sales report and IFF payment. Of course, if you report something as a GSA sale and the buying agency does not, the Schedule sales amounts on FPDS vs SSQ* may differ greatly. " This is a concern even though it would seem to contradict the FAR clause you cited. Has anyone else encountered this situation?