Government Contracting Blog

As a result of the Trump Administration’s April 2025 Executive Order (EO) directing for the rewrite of the Federal Acquisition Regulation (FAR), the FAR Council initiated the Revolutionary FAR Overhaul (RFO) effort. The goal of the RFO is to ensure the FAR only contains statutory rules that enhance clarity, resulting in more efficient procurement processes. Federal agencies have been implementing rewritten FAR parts through their own class deviations.

As a new calendar year begins, it’s important to review key events that occurred within the federal contracting world recently to prepare for a successful year for your GSA Multiple Award Schedule (MAS) contract. Forty years ago, the Federal Acquisition Regulation (FAR) was established as a “rulebook” featuring policies and regulations that would guide federal agencies during the procurement of supplies and services, totaling over 2,000 pages of content.

Government purchasers frequently utilize the GSA Multiple Award Schedule (MAS) Program to procure innovative Information Technology (IT) products and services that are available commercially from contractors. State and local governments, educational institutions, and other entities can also be eligible to purchase from GSA Schedule contractors’ IT offerings through the Cooperative Purchasing Program.

GSA Schedule contractors must be compliant with multiple rules and regulations throughout their contracts’ duration, and any agency-specific policies as they complete task orders. By having a GSA Schedule contract awarded, a company is not guaranteed to receive sales. A GSA Schedule is a non-funded contract. To earn revenue, contractors will need to compete to win task orders. For contractors who sell products, federal buyers will also have the opportunity to purchase directly from contractors’ available offerings through GSA Advantage! if they are under the Mirco-Purchase Threshold (MPT).

GSA utilizes Special Item Numbers (SINs) to categorize the product or service offerings contractors can have awarded on the Multiple Award Schedule (MAS). Many SINs require contractors’ or offerors’ services to meet specific standards or regulations to have the SIN awarded. A popular SIN that limits the types of services vendors can provide is the Engineering Services SIN or SIN 541330ENG. For example, traditional architect-engineer (A-E) services are not allowed to be sold through this SIN or any other SIN in general. However, the Engineering SIN is not the only SIN that limits engineering firms in their service offerings; the Environmental Consulting Services SIN also requires contractors or offerors looking to add this SIN to meet a few requirements.

In the recently released Multiple Award Schedule (MAS) Solicitation Refresh #28, GSA restructured the requirements for new offerors or existing contractors proposing products that they do not manufacture, and instead, resell. Prior to this Solicitation Refresh, new offerors or current contractors adding products they did not manufacture to their GSA Schedule contract or proposal were required to submit a Letter of Supply to demonstrate they have the authority to distribute these products. However, GSA has now restricted the Letter of Supply requirement to only resellers under Large Category F (Information Technology) and the Printing and Photographic Equipment Subcategory within Large Category A (Office Management).