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.
GSA MAS Solicitation Refresh #31 Makes TDR Mandatory for All Contractors
GSA has slowly rolled out Transactional Data Reporting (TDR) since the pilot was created in 2016. As a reminder, TDR was created to collect transaction-level data on products and services through the MAS Program. It serves as an alternative form of reporting from the legacy Commercial Sales Practices (CSP).
From the start, only certain Special Item Numbers (SINs) were eligible, but in the past several months, GSA has begun opening it up to more contractors including contractors who hold product SINs. With MAS Solicitation Refresh #31, GSA will make TDR mandatory for ALL MAS contractors. This means Commercial Sales Practices and the Price Reductions Clause that goes with it will be removed from the Solicitation. This is a big deal for the MAS Program, because it’ll change the way many contractors report their sales.
So, as a current or prospective contractor, what do you do about this change?
Current Non-TDR Offers
If you have an offer in for the MAS Program and its under Commercial Sales Practices, GSA advises you to withdraw your offer and resubmit under TDR requirements. If you do not eventually withdraw your offer, it’ll be rejected by GSA.
Existing Non-TDR Contractors
If you were not eligible for TDR before this Refresh, but you already hold a GSA Schedule, you’re probably asking what’s next. First, GSA will issue a Mass Modification to “Participate in TDR” to all MAS contractors who have not yet transitioned. The Mass Mod date will align with the beginning of the next sales reporting quarter. You will have 90 days to go in the Mass Mod system and accept this modification once released.
Once the modification is out, the timeline begins, but it doesn’t happen all at once. For example, if the “Participate in TDR” Mass Mod is initiated in February 2026, the TDR begin date wouldn’t be until the first date of the next sales reporting quarter which is April 1, 2026. You are required to capture transactional data beginning on the effective date of the Participate in TDR modification (in this example that would be April 1, 2026).
Price Reductions Clause liability will end on the 1st day of the next sales reporting quarter following the execution of the Participate in TDR mod.
GSA Proposes GSAR Clause to Safeguard AI Systems
This is a new addition to this Refresh, and it's one of the main reasons the timeline was pushed from February to March/April. It may seem kind of hidden in the update, but it's not to be ignored. Last week, GSA proposed GSAR clause 552.239-7001, Basic Safeguarding of Artificial Intelligence Systems (FEB 2026), which outlines stricter requirements for contractors' use of AI.
The main proposed requirements to watch out for are:
- Contractors must use American AI systems. Foreign AI systems are banned.
- Agencies will own all data outputs and custom AI developments made during the course of the contract.
- All AI systems used in performance of contract must be disclosed.
- Government data cannot be used for AI model training or improvement.
- Contractors are completely responsibly for AI service provider compliance, even if they aren't a subcontractor.
Some of these guardrails may be difficult to navigate, especially ensuring your third-party AI service provider is complying with requirements. However, this is not set in stone yet--GSA has opened a comment period from March 6 - March 20, so be sure to voice your opinion.
Startup Springboard Offers Will Be Limited to ITC Contractors
Another update in MAS Solicitation Refresh #31 is bringing the Startup Springboard Program back to its roots—the program will now be limited to offerors who also quality for the FASt Lane Program. FASt Lane is only eligible for offers and modifications under the Information Technology Category (ITC). This means only newer firms (in business less than 2 years) proposing ITC offerings that are agency-sponsored AND meet FASt Lane criteria can use the Startup Springboard pathway.
To participate, contractors must:
- Be assigned to an ITC contracting officer
- Submit only ITC Special Item Numbers (with the exception of the ancillary SIN)
- Be tied to an eligible federal IT initiative
- Provide a written request from a customer agency
- Meet strict response timelines for offer and modification reviews
The Startup Springboard was created for companies who have not been in business for at least two years to use other experience (such as relevant corporate and past project experience from key personnel). It was originally reserved for IT companies and was modified to all Large Categories a few years ago. With Refresh #31, it’ll revert back to IT companies and add the caveat that they must be qualified for the FASt Lane Program as well.
Additional Overall Refresh #31 Updates
In addition to expanding the TDR Program and changing requirements for the Startup Springboard Program, GSA plans to make a few other solicitation-wide updates. These include:
- GSA will update ‘Firearms & Ammunition’ language in each Large Category attachment explicitly excluding foreign replica weapons and inert ordnance from the scope of the MAS Program.
- Incorporate clause and provision updates to include:
- TDR related updates
- Various clause/provision updates to align with the RFO
- Updates as necessary, through Federal Acquisition Circular (FAC) 2025-06
Updates to Specific Large Categories and Special Item Numbers (SINs)
In every Solicitation Refresh, there’s more specific updates to Large Categories and Special Item Numbers (SINs). We’ll review them below:
Office Management (A)
In Large Category A, or Office Management, GSA revised a few SIN instructions.
- For SINs 339940 - Office Products, 339940OS4 OS4 Office Products and Supplies, and 339940SVC Office Supply Support Services, GSA added a clarification regarding the FOB Note. The FOB is destination with the exception of freight prepaid for 70 lbs. or more.
- The subcategory instructions will be revised for SINs 339940OS4 and 339940: All references to the “entire catalog” and/or the 80/20 rule will be removed as well as any references to furniture, restroom products, or IT being authorized for award under Subcategory A09 SINs.
- SIN instructions will also be revised for SIN 333249, under the Printing and Photographic Equipment subcategory.
Human Capital (D)
In Human Capital (D), there are a few updates:
- SIN instructions will be added for SIN 524292 Separation and Retirement to include HCBRM subfunction titles for consistency.
- The SIN description/instructions will be revised for SIN 54161 Agency Human Capital Evaluation, SIN 541612 EPM Employee Performance Management, SIN 541612ER Employee Relations, SIN 541612HC Agency Human Capital Strategy, Policy and Operations, SIN 56131 Talent Acquisition, SIN 611430TD Talent Development
Miscellaneous (G)
In the Miscellaneous Large Category (G), GSA will revise the OLM (Order-Level Materials) SIN instructions to eliminate the subcategory limitation, allowing it to be used as any other SIN under the Multiple Award Schedule (MAS).
It’s important to note here that the Revolutionary Federal Acquisition Regulation (FAR) Overhaul, or RFO, has altered the way in which “open market items” are allowed within the MAS Program. There is now a more structured, OLM-SIN–based approach, meaning items that were once accepted as general “open market” additions must now meet the specific OLM requirements outlined in GSAR 538.71 (GSA Class Deviation RFO-2025-GSAR 538) and GSAR 538.72.
Because of these changes, GSA recommends that you add the OLM SIN. All current MAS contractors who do not yet have the OLM SIN on their contract will be offered a one-time Mass Modification to add the OLM SIN.
Professional Services (H)
In the Professional Services category, several SIN instructions were revised including:
- SIN 541211 Auditing Services
- SIN 611TRAINAW Defense Acquisition Workforce Improvement Act (DAWIA) and Federal Acquisition Certification in Contracting (FAC-C) Professional Development Training for Acquisition Workforce Personnel
- SIN 611430 Professional and Management Development Training
Transportation and Logistics Services (K)
In Large Category K, Transportation and Logistics Services, changes were made including:
- Revise SIN instructions for SIN 488190 Aircraft Components, Maintenance, Repair Services, Extended Warranties, And Maintenance Agreements to remove all references to Original Equipment Manufacturer (OEM).
- Revise the SIN-specific template for 492110 Package Delivery and Freight Trucking & 492210 Local Courier Delivery Services by removing the ‘Instructions’ tab from each PPT, as all applicable terms are already included in the MAS Solicitation.
- Revise the SIN-specific template for SINs 485 Ground Transportation & 532111 Automotive equipment rental and leasing, Rental Supplemental Vehicle Program (RSVP) by removing the ‘Instructions’ tab from each PPT, as all applicable terms are already included in the MAS Solicitation.
Travel (L)
And lastly, in the Travel Category (L), GSA has several updates to SINs, including:
- Revise the SIN-specific template for SIN 531 Employee Relocation by removing the ‘Instructions’ tab from each PPT, as all applicable terms are already included in the MAS Solicitation.
- Revise the SIN-specific template for SIN 531110 Long Term Lodging by removing the ‘Instructions’ tab from each PPT, as all applicable terms are already included in the MAS Solicitation.
- Revise SIN-specific template for SIN 561510 Travel Agent Services Price Proposal Template located on the Required templates for MAS offer and the Multiple Award Schedule pages.
- Revise the SIN-specific template for SIN 531110 Long Term Lodging by removing the ‘Instructions’ tab from each PPT, as all applicable terms are already included in the MAS Solicitation Revise Statement of Work (SOW) for SIN 561510 Travel Agent Services located on the Multiple Award Schedule page.
- Revise Statement of Work (SOW) for SIN 561510 Travel Agent Services located on the Multiple Award Schedule page.
More in depth information on these changes in Travel and all the other Large Categories can be found in this GSA document.
Preparing for MAS Solicitation Refresh #31
We expect Solicitation Refresh #31 to be released sometime in March or April. You can find more information about the webinar on GSA’s Interact post. Once the Refresh is released, contractors have 60 days to review and accept the modification(s) in the Mass Mod System. This is a shorter timeline than the usual 90 days, so we recommend you act right away once it's released. It’s important to remember that only authorized negotiators on your GSA Schedule can access this site and acknowledge the changes.
This is one of many updates to the MAS Program we expect to see in 2026. To keep up with future changes, check out our blog and our monthly newsletter. If you have questions about your GSA Schedule or accepting Mass Modifications, one of our consultants would be happy to help you.
