GSA is on a roll with Multiple Award Schedule (MAS) Solicitation Refreshes. Refresh #21 is anticipated to be released in May 2024. This refresh will be followed by a Mass Modification, giving contractors 90 days to review the changes and accept the Refresh. If you’ve read a blog or two about our refreshes before, you know the drill—let’s review the changes we expect to see in this Refresh and what it may mean to you as a contractor.
Overall Changes to MAS Solicitation Refresh #21
First, let’s cover the updates that apply to all GSA Schedule contractors, regardless of the Large Categories or Special Item Numbers (SINs) they sell under. The first change in the solicitation is to implement a minor revision to SCP-FSS-001 Instructions Applicable to All Offerors. This will clarify that the 12-month waiting period and additional documentation requirements apply to Joint Venture (JV) partners who held a previous Schedule contract that was canceled/allowed to expire due to little or no sales or noncompliance.
Next, GSA added the following note to General Services Acquisition Manual (GSAM) clause 552.238-83, about the examination or records by GSA:
The types of books, documents, papers and records shall include but are not be limited to:
- Eligible users of the GSA Sources of Supply and Services, as defined by OGP 4800.2I and/or subsequent orders
- Basis of Award customers, 552.238-81 Price Reductions, and 552.238-80 Industrial Funding Fee and Sales Reporting
- Verifying CSP-1 Form accuracy and completeness
- GSA MAS Contractor Team Arrangements (CTAs)
- Authorized Dealers incorporated into the MAS contract by the Contracting Officer.
This means that the contractor agrees GSA or any other duly authorized representative can have access and the right to examine to the documents above related to overbillings, billing errors, or related pricing compliance of their GSA Schedule. This clause already existed, but GSA is making it more clear what documents the legislation allows examination of.
Following the same cadence as above, GSA added a note to Federal Acquisition Regulation (FAR) clause 52.232-36, Payment by Third Party (in lieu of payment directly from government customer), stating that credit card fees or convenience fees may not be charged to the end customer.
And as usual, GSA plans to incorporate clause and provision updates, as necessary, through certain regulation bodies, specifically the Federal Acquisition Circular (FAC) 2024-05 and GSAR Change 179.
Transactional Data Reporting (TDR) Changes
A few months ago, we talked about GSA implementing new Transactional Data Reporting (TDR) fields and initiatives to improve the program. In MAS Solicitation Refresh #21, GSA will formally add the 4 optional TDR reporting fields.
- Order Date
- Ship Date
- Zip Code Shipped To
- Federal Customer – Treasury Agency Code
At first these fields will be optional, but they may become mandatory as the implementation period ends. These changes were created to address data gaps in TDR and also make it possible to monitor pricing compliance, analyze data by location, access cycle times and contract compliance, and analyze data by treasury agency code.
Changes to Specific Large Categories or SINs
GSA also has planned changes for specific offerings depending on which Large Category(ies) and SIN(s) you sell under. The first change in this section, however, applies to ALL Large Categories.
This update will add a standard “General Information” section, clearly defining the scope of the MAS Solicitation regarding firearms, live ammunition, explosives, and artillery weapons. The new language will read:
GSA will not award weapons such as firearms, live ammunition, explosives, and artillery weapons under this Solicitation. This also includes components that are solely used to produce functional weapons. Components that will not be awarded under this Solicitation include, but are not limited to, barrels, chambers, bolts, trigger groups, stock, magazines, rockets, grenades, grenade launchers, mines and mortars, cases, primers, powder, and projectiles.
This exclusion does not apply to non-lethal ammunition types intended to be used for training, safety, and marking purposes.
There is often a question about what is allowed on GSA Schedules regarding firearms and ammunition, so hopefully this clears it up for prospective offerors.
Now, let’s dive into the specific categories.
Office Management (A)
In this category, the following SIN descriptions will be updated to include multifunction printers (MFP) and multifunction devices (MFD).
- 333316C - Copiers and Digital Duplicating Equipment
- 333316CPC - Cost-per-Copy Plan for Copiers (to include Analog, Digital, Multifunctional and Engineer Copiers)
- 333316F - Flat Rate Monthly Fee for Copiers (to include Analog, Digital, Multifunctional and Engineer Copiers)
- 333316OS - Overseas Copiers and Supplies
- 532420C - Copier Rental Solutions
- 532420LC - Operating Lease Plan For Copiers
- 532420LTOP - Lease to Ownership Plans (LTOP) Copier
Information Technology (F)
In the Information Technology category, there are several changes. The first one is to add a standard “General Information” section to add language to clarify payment for software licenses delivered via Software as a Service (SaaS). In summary, this note says upfront payment for software licenses delivered or accessed via SaaS are not considered advance payment. The full note can be found in GSA’s Significant Changes document.
Next, in the Electronic Commerce Subcategory, the language below will be removed from SIN 54151ECOM Electronic Commerce and Subscription Services:
All services shall be billed in arrears in accordance with 31 U.S.C. 3324.
Similarly, under SIN 541519ICAM - Identity, Credentialing and Access Management (ICAM) and SIN 561422 - Automated Contact Center Solutions (ACCS), the following language will be removed:
All services shall be billed in arrears in accordance with 31 U.S.C. 3324.
For SINs 518210C - Cloud Computing and Cloud Related IT Professional Services and 518210FM - Financial Management Quality Service Management Office (FM QSMO) Core Financial Management (FM) Solutions and IT Professional Services, the SIN instructions will be revised to remove all language related to:
- “must be billed in arrears”.
- “must adhere to the ‘pay as you go’ pricing model and must be billed in arrears in accordance with 31 U.S.C. 3324.
Under the “Solutions Subcategory SIN 518210C, GSA will revise the Specific Information for Offerors document located on the MAS website.
In the IT category, GSA also plans to establish a new SIN, 541519CSP - Credential Service Provider. This SIN will offer agencies a managed service offering for component or full service Credential Service Providers (CSPs) that meet the requirements of NIST SP 800-63 Digital Identity Guidelines (current version), to include public facing and enterprise.
And lastly, in the Telecommunications Subcategory, GSA will remove the language below for SIN 517410 - Commercial Satellite Communications Solutions (COMSATCOM) and SIN 517312 - Wireless Mobility Solutions:
All services shall be billed in arrears in accordance with 31 U.S.C. 3324.
Professional Services (H)
In the Professional Services Large Category, GSA has two revisions planned. The first one is for SIN 541990IPS - Data Breach Response and Identity Protection. GSA will revise the four supplemental proposal documents included with the SIN. Here are the changes we expect to see:
For Document 1C (SSP Template):
- Update the System Security Plan template IAW with the latest version of NIST SP 800-53.
For Documents 1A (Important Definitions) and 1B (Additional Proposal Instructions):
- Update hyperlinks to the NIST CPRT catalog which shows all of the latest documentation instead of the individual documents.
- Remove references to specific revisions and replace with "(latest revision)", and added formatting for emphasis.
Additionally, GSA will add language to ALL the documents EXCEPT 1C (SSP template) to further explain how SSP changes (outside of GSA reqs.) are handled when they are requested at the order level.
Lastly, GSA will add formatting to the last page of SIN 541990IPS ordering guide to underscore the order reporting requirements.
Travel (L)
In Large Category L, Travel, there is one update. For SIN 561510 - Travel Agent Services, GSA plans to revise the Statement of Work (SOW) to account for changes in commercial travel capabilities and services offered by the Travel Management Companies (TMCs).
The next generation of the ETS program (ETSNext) is using the model that will no longer be embedded and included as part of the ETSNext contract. Instead, each individual civilian agency is responsible for requesting Travel Agent Services.
Preparing for this Solicitation Refresh and Future GSA Schedule Updates
Although some of the changes in Refresh #21 may not apply to you, ALL GSA contractors must accept the Mass Modification in the Mass Mod System. Once the Refresh is released and the accompanying Mass Mod is sent out, contractors will have 90 days to accept it.
It’s important to remember that only authorized negotiators with a valid GSA FAS ID will be able to accept the Mass Mod. To add someone to your list of authorized negotiators, you can submit a modification in the eMod system.
To stay updated on future GSA Solicitation Refreshes, 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.
