GSA Incorporates Revolutionary FAR Overhaul (RFO) Updates in MAS Solicitation Refresh #30

Updated to reflect GSA changes to solicitation draft on November 7, 2025

With all the recent changes to procurement, it was only a matter of time before another Multiple Award Schedule (MAS) Solicitation Refresh came out. GSA recently announced Refresh #30, which is anticipated to be released sometime in November 2025 accompanied by a Mass Modification. This Refresh mostly covers Solicitation-wide updates related to the Revolutionary Federal Acquisition Regulation (FAR) Overhaul, or RFO. Here’s everything you need to know about this Refresh and what it means for your GSA Schedule contract.

Clause and Provision Updates in MAS Refresh #30

Refresh #30 includes a laundry list of clauses to be updated, added, replaced, or removed in the Solicitation to align with deviations in the FAR and General Services Administration Regulation (GSAR). These are all a result of the RFO. We’ll highlight a few below, but the full list can be found in GSA’s interact post.

On 11/5, GSA published some updates to the draft Solicitation Refresh including:

• The requirement for the Professional Compensation Plan has been removed from SCP-FSS-001 (SCP paragraph (j)(3)(xi)).
• The requirement for contractors to provide evidence of an uninterrupted source of supply throughout contract performance will be removed from clause I-FSS-644, Products Offered and Sold by Vendors Other than the Manufacturer and other general edits.
• The language in the “Drones/Unmanned Aircraft Systems" section has been revised. This specific update affects the "General Information" section across ALL Large Categories

Additional clauses that will be UPDATED include: 

• 52.223-2, Reporting of Biobased Products Under Service and Construction Contracts
  (DEVIATION)
• 52.223-23, Sustainable Products (DEVIATION)
• 52.209-6, Protecting the Government’s Interest When Subcontracting With Contractors
  Debarred, Suspended, Proposed for Debarment, or Voluntarily Excluded (DEVIATION)
• 552.212-4, Contract Terms and Conditions - Commercial Products and Commercial
  Services (DEVIATION FAR 52.212-4)
• 552.212-4, Contract Terms and Conditions - Commercial Products and Commercial
  Services (ALT I) (DEVIATION FAR 52.212-4)

An example of deviations to be ADDED (and REPLACE the original version of these clauses, which will be removed):

• 52.204-7, System for Award Management (NOV 2024) (DEVIATION NOV 2025)
• 52.209-2, Prohibition on Contracting With Inverted Domestic
  Corporations-Representation (NOV 2015) (DEVIATION NOV 2025)
• 52.209-5, Certification Regarding Responsibility Matters (AUG 2020) (DEVIATION NOV
  2025)
• 52.209-7, Information Regarding Responsibility Matters (OCT 2018) (DEVIATION NOV
  2025)
• 52.212-1, Instructions to Offerors—Commercial Products and Commercial Services
  (SEP 2023) (DEVIATION NOV 2025)
• 52.215-20, Requirements for Certified Cost or Pricing Data and Data Other Than
  Certified Cost or Pricing Data (NOV 2021) (ALTERNATE IV - OCT 2010) (DEVIATION
  NOV 2025)
• 52.215-6, Place of Performance (OCT 1997) (DEVIATION NOV 2025)
• 52.219-1 Small Business Program Representations (FEB 2024) (DEVIATION NOV
  2025)
• 52.233-2, Service of Protest (SEP 2006) (DEVIATION NOV 2025)

Deviations to be newly ADDED to the Solicitation are:

• 52.240-90, Security Prohibitions and Exclusions Representations and Certifications
  (NOV 2025) (DEVIATION)
• 52.209-11, Representations By Corporations Regarding Delinquent Tax Liability or A
  Felony Conviction Under Any Federal Law (FEB 2016) (DEVIATION NOV 2025)
• 52.240-91, Security Prohibitions and Exclusions (NOV 2025) (ALTERNATE I - NOV
  2025) (DEVIATION)
• 52.240-93, Basic Safeguarding of Covered Contractor Information Systems (NOV 2025)
  (DEVIATION)
• 52.208-90, Government Supply Sources (NOV 2025) (DEVIATION)

Since this list was only five deviations long, we included all of the newly added clauses to the Solicitation.

A sample of clauses that will be DELETED from the Solicitation include:

• 52.204-17 Ownership Or Control of Offeror (JUL 2016)
• 52.204-20 Predecessor of Offeror (JUL 2016)
• 52.204-24 Representation Regarding Certain Telecommunications and Video
  Surveillance Services or Equipment (NOV 2021)
• 52.204-29 Federal Acquisition Supply Chain Security Act Orders—Representation and
  Disclosures (DEC 2023)
• 52.212-3 Offeror Representations and Certifications - Commercial Products and
  Commercial Services (MAY 2024) (DEVIATION FEB 2025)
• 552.238-115, Special Ordering Procedures for The Acquisition of Order-Level Materials (SEP 2024)
• SCP-FSS-007, Special Proposal Instructions for Order-Level Materials Special Item Number (DEC 2019) 
• 52.204-21 Basic Safeguarding of Covered Contractor Information Systems (NOV 2021)

MAS Ordering Procedures Statement

The next update in MAS Solicitation Refresh #30 is adding a statement to direct GSA Schedule contractors to GSA.gov for more information on ordering procedures. The note reads:

Ordering activities must follow procedures outlined in RFO GSAM Subpart 538.71— Federal Supply Schedule Ordering Procedures for placing orders and establishing blanket purchase agreements (BPAs) against Federal Supply Schedule (FSS) contracts. Additional guidance can be found at http://www.gsa.gov/schedules.

Something that is not explicitly mentioned in the Refresh #30 changes draft, but should be mentioned, is that GSAM Subpart 538.71—Federal Supply Schedule Ordering Procedures is a new class deviation that was created from the original FAR 8.4 FSS Ordering Procedures clause. The FSS ordering procedures have been revised and moved from FAR 8.4 to this new subpart/supplement in the GSAM. The changes were made to include only essential requirements needed to place orders and establish Blanket Purchase Agreements (BPAs) against FSS contracts.

Changes to the Order Level Materials (OLM) SIN

The only Large Category-specific update GSA plans to make in Refresh #30 is with the Order Level Materials (OLM) Special Item Number (SIN) in the Miscellaneous Category (G). GSA plans to remove certain clauses as showcased above. These are OLM SIN level regulations: 

• 552.238-115, Special Ordering Procedures for The Acquisition of Order-Level Materials (SEP 2024)
• SCP-FSS-007, Special Proposal Instructions for Order-Level Materials Special Item Number (DEC 2019) 

To quickly review, the OLM SIN consists of supplies and/or services not directly on a contractor’s Schedule but added at the task order level to support another SIN as part of an order. There are currently 60-OLM eligible subcategories under the MAS Program, and we expect them to remain the same for now.

Refresh #30 originally planned to remove the 33% OLM cap which is reflected in the FAR now, but GSA has revised the draft to state that OLM subcategory limitations will stay in effect through Refresh #30 and be removed in a future Refresh.

Accepting the Mass Modification for Solicitation Refresh #30

Contractors will have 90 days to review and accept the modification in the Mass Mod System once it’s released in November. Only authorized negotiators on your GSA Schedule can access the Mass Mod system and accept the changes.

To keep up with future govcon changes and updates, check out our blog and our monthly newsletter. If you need help accepting the Mass Modification or you have questions about your GSA Schedule, one of our consultants would be happy to help you.