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

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 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.

GSA separates these clauses into three sections: deviations to be added and replace current clauses, new clause deviations to be added, and clauses to be deleted. We’ll highlight a few below, but the full list can be found in GSA’s interact post.

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

• 204-7, System for Award Management (NOV 2024) (DEVIATION AUG 2025)
• 209-2, Prohibition on Contracting With Inverted Domestic Corporations-Representation (NOV 2015) (DEVIATION AUG 2025)
• 209-5, Certification Regarding Responsibility Matters (AUG 2020) (DEVIATION AUG 2025)
• 209-7, Information Regarding Responsibility Matters (OCT 2018) (DEVIATION AUG 2025)
• 212-1, Instructions to Offerors—Commercial Products and Commercial Services (SEP 2023) (DEVIATION AUG 2025)
• 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 SEP 2025)
• 215-6, Place of Performance (OCT 1997) (DEVIATION SEP 2025)
• 219-1 Small Business Program Representations (FEB 2024) (DEVIATION SEP 2025)
• 223-1, Biobased Product Certification (MAY 2024) (DEVIATION SEP 2025)
• 233-2, Service of Protest (SEP 2006) (DEVIATION AUG 2025)

Deviations to be newly added to the Solicitation are:

• 240-90, Security Prohibitions and Exclusions Representations and Certifications (AUG 2025) (DEVIATION)
• 209-11, Representations By Corporations Regarding Delinquent Tax Liability or A Felony Conviction Under Any Federal Law (FEB 2016) (DEVIATION AUG 2025)
• 240-91, Security Prohibitions and Exclusions (AUG 2025) (ALTERNATE I - AUG 2025) (DEVIATION)
• 240-93, Basic Safeguarding of Covered Contractor Information Systems (AUG 2025) (DEVIATION)
• 208-10, Government Supply Sources (AUG 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:

• 204-17 Ownership Or Control of Offeror (JUL 2016)
• 204-20 Predecessor of Offeror (JUL 2016)
• 204-24 Representation Regarding Certain Telecommunications and Video Surveillance Services or Equipment (NOV 2021)
• 204-29 Federal Acquisition Supply Chain Security Act Orders—Representation and Disclosures (DEC 2023)
• 212-3 Offeror Representations and Certifications - Commercial Products and Commercial Services (MAY 2024) (DEVIATION FEB 2025)
• 225-25 Prohibition on Contracting With Entities Engaging In Certain Activities or Transactions Relating to Iran Representations and Certifications (AUG 2018)
• 222-46 Evaluation of Compensation for Professional Employees (FEB 1993)
• 204-18 Commercial and Government Entity Code Maintenance (JUL 2016)
• 204-2 Security Requirements (MAR 2021)
• 204-21 Basic Safeguarding of Covered Contractor Information Systems (NOV 2021)

GSA also plans to update provision SCP-FSS-001 to align with the FAR and GSAM updates in the RFO. These will include administrative changes to update references to better reflect the new RFO content in the solicitation.

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 will revise the OLM SIN description to align with updates in the Revolutionary FAR Overhaul.

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.

One key thing to point out in this Refresh is GSA adds a link to the OLM SIN description to RFO 538.7104-2 Order-level materials. It’s not specifically stated in this draft of the Refresh, but in the RFO process, GSA removed the 33% cap on OLMs in an order, giving contractors more room to add OLMs at the task order level.

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.