Government Contracting Blog

When GSA released their updated post for Multiple Award Schedule (MAS) Solicitation Refresh #31 recently, they quietly slipped in a newly proposed clause that would govern AI use in federal contracts. This proposed clause, GSAR 552.239-700, Basic Safeguarding of Artificial Intelligence Systems, introduces significant requirements for companies who are using AI in any capacity in federal contracts. GSA originally gave contractors until March 20 to leave their feedback, but the period was extended to April 3, 2026, and GSA is pushing the AI changes to MAS Refresh #32.

Keeping up with your GSA Multiple Award Schedule (MAS) is important now more than ever. GSA is looking for ways to cut costs and increase efficiency, and contractors who are not maintaining contract compliance or meeting their minimum sales requirement are at risk of contract cancellation. While this has always been a risk, GSA is really enforcing the rules for contractors who are not succeeding in the MAS Program.

GSA Schedule contract compliance is not an easy task--there are so many requirements to abide by and keep up with, and frankly, it can be overwhelming. GSA Schedule contracts can be a great asset to your company, but they require time and dedication. One of the most important parts of maintaining contract compliance is sales reporting. This is the General Services Administration’s (GSA) way of tracking how your company is performing as a contractor, and collecting data on the products and services that are being acquired through the Multiple Award Schedule (MAS) Program.

The General Services Administration (GSA) is working on consolidating the certification framework for cloud service providers who are new to the FedRAMP Program. Right now, a full traditional security assessment and review is expensive and cumbersome for the government and creates barriers for cloud service providers looking to get FedRAMP certified. The goal is to reduce the initial review burden with consolidated rules that are anticipated to be published by the end of June 2026, and retire the FedRAMP Ready designation program. If you offer cloud services and are currently doing business with the federal government, or plan to in the future, read on to learn more about these changes.

This probably isn't the first time you're hearing about Multiple Award Schedule (MAS) Solicitation Refresh #31, but it might be the first time you're hearing of GSA's latest updates to the Refresh since the timeline was extended to March/April. GSA is planning significant changes with Refresh #31, including making Transactional Data Reporting (TDR) mandatory for all GSA MAS contractors, and proposing strict AI provisions. This is a big move for the MAS Program because Commercial Sales Practices (CSP) and reporting will no longer be a part of the Solicitation, and contractors may have to rethink the way they use AI. GSA also plans to make several other updates surrounding the Startup Springboard Program, clause provisions, and specific Large Categories. Since GSA is giving industry a brief opportunity to comment on the AI provisions, it's important you know what's to come in the next few months.

It's a great time to be in the public sector if you offer professional services. Earlier this year, GSA opened Phase II of their OASIS+ contract vehicle and expanded the scope with 5 new domains. There is currently no deadline for submission or limit on contract awards, so we're encouraging companies to get their foot in the door now. If you offer non-IT professional services, this vehicle might be for you. Let's review what OASIS+ is and how your business may be able to benefit from the contract.