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GSA Removes 20-year MAS Requirement and Introduces AI Clause in Solicitation Refresh #34

Written by Stephanie Hagan | Oct 27, 2026, 3:35:27 PM

GSA is already lining up the next round of changes to the Multiple Award Schedule (MAS) Solicitation with Refresh #34. This Refresh is not one to skim over, because it introduces significant changes including the removal of the 20-year limit on Schedule contracts, and the addition of GSA’s highly anticipated AI clause.

Refresh #34 is expected to be released around mid-November (12th or 13th), so now is the time to review the changes and make sure you're ready for the Mass Modification. Here’s what we know about the draft Refresh changes so far.

Changes to the Overall MAS Solicitation

GSA is updating the SCP-FSS-001 Instructions Applicable to All Offerors in 3 different areas:

    • GSAR Overhaul Wave 4 updates, covering GSAR Part 538 (Federal Supply Schedule Program) and GSAR Part 539 (Acquisition of Information and Communication Technology)
    • GSA Class Deviation CD-2026-04, which covers FSS Domestic End Product Certification
    • An OMB memo on Covered Nitrile Gloves

We'll go through each one below.

Removal of the 20-Year Limit on MAS Contracts

GSA describes the Wave 4 (final) updates to GSAR Part 538 as modernizing the FSS Program through "evergreen contracting". In other words, GSA is removing the 20-year limit on GSA Schedules.

As the Solicitation is currently written, MAS contracts end at 20 years (provided you have extended every 5 years with an option extension). Contractors can choose to continue and get a new GSA Schedule contract under the Streamlined Acquisition process, but GSA plans to take this away and continue with the 5-year option extensions indefinitely.

Right now, we don’t have a lot of information as to what the timeline will look like. GSA recommends that contractors nearing the end of their 20 years should still continue the Streamlined Acquisition process, since we don’t know how long the implementation will take after Refresh #34 is released. GSA mentioned they will be giving more information on the short-term and long-term plans soon.

GSAR Part 538 Clause Changes

Also, as part of the final wave in GSAR Part 538, GSA plans to add/delete/update clauses to reflect the last wave of changes coming from the Federal Acquisition Regulation Overhaul (RFO) in this section.

All in all, GSA is deleting 41 GSAR provisions and clauses, removing eight (8) FAS FSS clauses, and adding five (5) new GSAR clauses (552.238-190 through -194). GSA says this consolidates existing GSAR clauses and folds in the FSS "homegrown" clauses. Once the dust settles, the remaining GSAR clauses will be:

    • 552.238-77, Pricing and Catalog Data
    • 552.238-79, Cancellation
    • 552.238-80, Transactional Data and Contract Fee Requirements
    • 552.238-82, Contractor Initiated Modifications
    • 552.238-83, Examination of Records by GSA (Federal Supply Schedules)
    • 552.238-112, Definitions—Federal Supply Schedule Contracts
    • 552.238-113, Authorities Supporting Use of Federal Supply Schedule Contracts
    • 552.238-115, Order-Level Materials Requirements
    • 552.238-116, Option to Extend the Term of the FSS Contract
    • 552.238-117, Failure to Provide Accurate Information—Price Adjustment
    • 552.238-190, Federal Supply Schedule Contractor Team Arrangements
    • 552.238-191, Federal Supply Schedule Contract Requirements
    • 552.238-192, Federal Supply Schedule Order-level Requirements
    • 552.238-193, Product Offering and Sales Requirements
    • 552.238-194, Sales Criteria
    • 552.516-90, Economic Price Adjustment

One thing that isn't changing in this wave: FSS ordering procedures in GSAR 538.71. GSA notes that those revisions were made through MAS Refresh #30 and are currently going through rulemaking.

For more on the overhaul, check out acquisition policy resources on GSA.gov and the Revolutionary FAR Overhaul (RFO) page on Acquisition.gov.

GSA’s New AI Clase

Under GSAR Part 539, GSA is creating a new AI-related clause (GSAR 552.239-7001) for GSA contracts, including the MAS Program. The clause is meant to protect government data and reduce other risks that come with large language model (LLM) systems.

If your company uses AI tools in delivering work under your Schedule, or sells AI-enabled products or services, this is a clause to read closely. The final clause has changed significantly from the draft, so you’ll want to check it out to see if it still impacts your company. You can learn more about the AI clause specifics in our recent blog.

New FSS Domestic End Product Certification (CD-2026-04)

In Refresh #34, GSA is also introducing a new clause, GSAR 552.238-130, Federal Supply Schedule (FSS) Domestic End Product Certificate (Sep 2026). Essentially, contractors will be able to voluntarily certify that their listed products are FSS domestic end products.

What counts as an "FSS domestic end product"? Well under the clause, a product has to meet all of the following:

    • Offered for sale on the offeror's or contractor's GSA FSS contract
    • Manufactured in the United States
    • If the product does not consist wholly or predominantly of iron or steel (or both), the cost of components mined, produced, or manufactured in the U.S. exceeds 75% of the cost of all its components
    • If the product does consist wholly or predominantly of iron or steel, the cost of foreign iron or steel is less than 5% of the total cost of all its components. Foreign iron or steel here includes, but isn't limited to, foreign iron or steel mill products (such as bar, billet, slab, wire, plate, or sheet), castings, or forgings used to make the iron or steel

Contractors who opt in to this certification will be able to use the new code in their catalog submission files in the Schedule Input Program (SIP), the Electronic Data Interchange (EDI), and the FAS Catalog Platform (FCP).

GSA intends to use this information to help buyers on GSA Advantage! identify FSS domestic end products.

Covered Nitrile Gloves

Following an OMB memorandum published August 31, 2026, GSA intends to move toward removing items from MAS contracts that fall within the scope of DHS's Best-in-Class PPE Safety Stock contract for domestically manufactured nitrile gloves.

Current offerings in that scope include powder-free, medical-grade nitrile gloves in 4 mil and 5 mil blue varieties and a 6 mil black variety. Before anything is removed, GSA plans to work directly with affected contractors to confirm which items are in scope and to consider contractor feedback before proceeding.

Large Category and SIN-Specific Changes in Refresh #34

Refresh #34 also includes changes in two specific Large Categories—Facilities (B) and Information Technology (F).

Facilities (B)

In the Facilities Maintenance and Repair Subcategory (B01), GSA is revising SIN 561210FAC, Facilities Support Services. The goal is to eliminate HVAC maintenance services as a standalone offering. GSA is removing the subgroup "HVAC Maintenance: Boilers, Chillers, Refrigeration, etc." and adding HVAC maintenance to the SIN note on service types that can't stand alone.

If you currently hold, or planned to offer, HVAC maintenance under this SIN, review the final note language carefully against your offering.

Information Technology (F)

In the IT Services Subcategory (F05), GSA is phasing out the voluntary Incident Response subgroup under SIN 54151HACS, Highly Adaptive Cybersecurity Services (HACS), at the end of FY 2027 (September 2027).

If you're in the Incident Response subgroup but don't hold the Incident Handling and Event Management (IHEM) subgroup, you can evaluate your eligibility and request placement in IHEM, which incorporates Incident Response capabilities.

Are You Ready for Refresh #34 and the Mass Modification?

Once GSA releases the final Refresh #34, you'll need to review and accept the Mass Modification within 90 days. We'll keep an eye on the final version and share any changes from this draft.

To stay up to date on future Solicitation Refreshes, check out our blog and sign up for our monthly newsletter. If you need help understanding how Refresh #34 affects your Schedule or accepting the Mass Modification once it's released, please feel free to reach out.