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GSA Questionnaire

If your company leases space to the federal government or manages federally leased properties, BOMA would like your feedback on two related issues. We respectfully ask for you to provide your feedback by COB August 17 in order for us to submit comments by August 24.

The General Services Administration (GSA) is seeking comments on a proposed certification and reporting requirement related to Executive Order 14398 and certain diversity, equity, and inclusion (DEI) workplace practices. Under this proposal, companies that lease property to the federal government may need to review existing policies, training programs, employment practices, and related documents before certifying compliance.

GSA estimates that reviewing the requirements, gathering information, completing the certification, and submitting the required documentation would take 1.167 hours. However, the notice does not clearly explain what constitutes a "response" for purposes of this estimate (e.g., whether it applies per company, per lease, per contract action, or some other reporting event). BOMA has requested additional clarification from GSA but has not yet received a response.

For purposes of this survey, please assume the estimate applies on a per-lease basis. BOMA is collecting member input to better understand the actual time, cost, and effort required to complete these activities and to help inform comments BOMA plans to submit to GSA and the Office of Management and Budget (OMB) before the August 24, 2026 GSA comment deadline.

Additionally, BOMA is seeking information about lease amendment language that some federal lessors have recently been asked to incorporate into existing leases, lease renewals, and future leases. BOMA has received reports that property owners and managers are being asked to add new provisions related to Executive Order 14398 without accompanying implementation guidance. The survey questions below are intended to help BOMA better understand the operational, legal, administrative, financing, and business impacts associated with reviewing, negotiating, and implementing those lease amendments.
1.GSA estimates that reviewing the requirements, gathering information, completing the certification, and submitting the required documentation would take 1.167 hours per response. Based on your organization's experience, is this estimate accurate?
2.Before your organization could certify compliance, which of the following activities would likely be required? (Select all that apply.)
3.Has GSA provided sufficient guidance for your organization to determine whether it complies with the proposed certification requirements?
4.Please identify any areas that remain unclear.
5.What additional costs (if any) do you anticipate incurring to evaluate and comply with the proposed certification requirements?
6.Please describe the primary drivers of those costs.
7.What changes could GSA make to reduce the burden on property owners and managers while still achieving its compliance objectives? (Select up to three.)
8.Additional comments or recommendations for GSA:
9.Has your organization received a request from GSA or another federal agency to incorporate Executive Order 14398-related language (including FAR Clause 52.222-90) into an existing lease, lease renewal, lease extension, or new lease?
10.If Yes, please identify the agency and approximate date received.
11.When the amendment request was received, what supporting information was provided? (Select all that apply.)
12.Before your organization could confidently sign or incorporate the amendment, which of the following would require review? (Select all that apply.)
13.Approximately how many total hours would be required before signing and implementing the amendment?
14.Optional: Please describe the activities that would drive most of this time requirement.
15.Which aspects of the amendment remain unclear to your organization? (Select all that apply.)
16.What impact, if any, could the amendment have on your organization's federal leasing activities? (Select all that apply.)
17.Please provide any examples or additional comments that may help BOMA understand the impact of these amendments.
18.Please provide your name and location