In April, the GSA Federal Acquisition Service (FAS) issued a Request for Information (RFI) to better understand how to align Multiple Award Schedule (MAS) pricing with commercial practices. They recently posted an article on GSA Interact outlining their takeaways from this RFI, opportunities to strengthen policies, and their next steps. In this blog, we’ll go over the RFI itself, the GSA’s response, and what this means for contractors.
What Did GSA’s Pricing RFI Ask?
The RFI sought industry feedback on two main topics: offering identical items under multiple Special Item Numbers (SINs) and offeror provided documentation to support “fair and reasonable” pricing determinations (specifically pertaining to large product offers).
The RFI included multiple questions under each topic, designed to help the GSA better understand how to align GSA requirements with commercial practices and ease the burden on both contractors and the GSA.
For example, offering identical items across multiple SINs is allowed under the MAS solicitation, but is an area where contractors sometimes run into difficulties. One question on the RFI asks contractors to provide examples of challenges that exist in getting identical items added under more than one SIN, to help the GSA better understand where problems are coming from.
Another question under this topic asks contractors how using the same labor category names and descriptions across MAS SINs as a standard practice for managing labor categories reduce administrative costs/burdens.
The second topic focuses on the pricing support requirements. The GSA noted in the RFI that they are “considering revising MAS instructions to only request pricing information that is needed to determine pricing is fair and reasonable.” In other words, they are considering reducing the amount of pricing support documentation needed.
While this may seem like a major change at first, they further clarified that they are only seeking feedback regarding supporting documentation for contractors with larger product catalogs, and that any potential changes would only apply to this group. Under this topic, they sought feedback on how to reduce the burden on contractors while still ensuring that the GSA has enough information to perform a thorough price analysis.
What Were GSA’s Key Takeaways?
In a post on GSA Interact in November 2024, GSA outlined their key takeaways after reviewing the responses to the RFI. The first takeaway was that removing or minimizing obstacles related to offering identical products and services across multiple SINs would align with offerors’ commercial practices, and enhance sales opportunities. This should not come as a surprise, since offering identical items across multiple SINs is already permitted under the solicitation, but it is nice to see the GSA taking contractors’ feedback into account.
The next takeaway was that updating solicitation instructions to prioritize the use of data already available within the government and/or obtained from sources other than the offeror can reduce industry burden and better align MAS solicitation requirements with the contract pricing policy in Federal Acquisition Regulation (FAR) subpart 15.4. We’ll discuss further what this means in the next section, but this is definitely good news for contractors.
The third takeaway was that there were several comments which addressed sampling methods and sample sizes that can be used for evaluating proposed MAS pricing. GSA stated that FAS plans to use this information to develop guidelines that improve effective and efficient market research, particularly for items with low market saturation.
The fourth and final takeaway from the RFI was that further expansion of the Transactional Data Reporting (TDR) initiative can provide a less-burdensome alternative to legacy pricing disclosure requirements. While we know that GSA is already intending to continue expanding TDR, this is a welcome reminder of the fact that more contractors want access to the program.
What Are GSA’s Next Steps?
Now that we’ve reviewed the GSA’s key takeaways, we’ll discuss what action they plan to take based on the information they’ve gathered. In the immediate future, they plan to issue a reminder to the FAS workforce (including Contracting Specialists and Contracting Officers who review GSA Schedule proposals and modifications).
The reminder will emphasize two points: first, reaffirming that offerors can offer identical products and services across multiple Special Item Numbers if the items are within scope, and second, FAS solicitations and the acquisition workforce must not dictate minimum experience or educational requirements to offerors proposing IT labor categories. This reminder does not indicate a change in policy, but is simply a way of reminding GSA employees of solicitation details that can sometimes cause friction.
In the long term, FAS intends to make changes to the MAS solicitation. Before they are incorporated into the solicitation, FAS plans to invite public comment on the changes, which include:
- A new draft FAS Policy and Procedure implementing GSAR Case 2020-G510, FSS Economic Price Adjustment, which was published as a final rule on September 4, 2024.
- Draft revisions to FAS Policy and Procedure 2021-05, Evaluation of FSS Program Pricing, to account for input from all MAS stakeholders and align with recent MAS pricing developments.
- Draft revisions to solicitation Price Proposal instructions that streamline documentation requirements and promote efficient evaluation of MAS offers.
Each of these changes is intended to help streamline the offer process and reduce the burden on both contractors and GSA. The change to the EPA clause is designed to consolidate EPA procedures into one clause, instead of the current four clauses. The FAS Policy and Procedure 2021-05 is intended to clarify evaluation procedures for offers, and the draft revisions to Price Proposal instructions are meant to help streamline the evaluation process.
Want to Know More About MAS Pricing?
This RFI addressed just a few of the GSA proposal pricing requirements and planned changes. If you want to learn more about the process, or what this RFI may mean for your business, reach out to Winvale. One of our expert consultants will be happy to help.
