If you hold a GSA Multiple Award Schedule (MAS) contract, you know the drill by now: GSA regularly refreshes the MAS Solicitation, and each update brings a new round of changes. GSA recently posted the draft for the newest Refresh, Solicitation Refresh #33, which is anticipated to be released sometime in September. Contractors will have 90 days to review and accept the Mass Modification that is released in tandem with this Refresh, so here’s a guide highlighting all the changes.
Changes to the Overall MAS Solicitation
GSA is planning on three main updates for the entire MAS Solicitation:
- Revisions to the SCP-FSS-001 Instructions Applicable to All Offerors, including a new supply chain security provision and clause, expanded FASt Lane eligibility, and a Class Deviation affecting the Trade Agreements Act (TAA) exemption for certain nonprofit agencies
- A new product substitution requirement added to the "General Information" section of every Large Category solicitation attachment
- Integration of the most recent Service Contract Labor Standards (SCLS) wage determinations
We’ll dig into each of these below.
New Supply Chain Security Provision and Clause Under GSAR Part 540
Through its Revolutionary GSAR Overhaul (RGO), GSA is reimagining its acquisition system and using this Refresh to formally add existing supply chain requirements to the GSA Acquisition Regulation (GSAR). As part of that effort, GSA is adding a new provision (552.540-70) and clause (552.540-71) under GSAR Part 540 aimed at strengthening the security and reliability of the products, services, and solutions offered on Schedule.
According to GSA, this new provision and clause are designed to:
- Formalize current supply chain requirements
- Establish a consistent, transparent, and uniform agency-wide framework to minimize inconsistencies
- Align with legislative and regulatory mandates
- Enhance overall security and threat mitigation efforts
GSA has also published a one-page flyer and FAQs with more detail on the implementation timeline, examples of supply chain risk, and what this means for offerors and contractors. You can also find this information on GSA.gov under the "Supply Chain Security" section of the "GSA Resources" tab.
Expanded FASt Lane Eligibility
One of the bigger changes in Refresh #33 is the expansion of FASt Lane eligibility beyond the IT Category (Large Category F) to all the Large Categories. It’s important to note this is ONLY for GSA Schedule offers right now, and NOT modifications. Those will be limited to the IT category, which we’ll discuss below.
Like the current FASt Lane requirements, offerors must also still demonstrate a real federal customer need for the products or services being offered. If the requirement is part of a listed eligible initiative, you must provide the information and documentation required in the FASt Lane Eligibility Checklist, such as the RFQ, RFI/Sources Sought, applicable SINs, and closing date. If the requirement is not a listed eligible initiative, you must provide a written request from the federal agency ordering activity explaining the need for your company and why expedited FASt Lane processing is needed.
Here’s what's staying the same:
- Startup Springboard participation will still be limited to contractors approved as FASt Lane participants. We are waiting on confirmation from GSA if this change means Springboard is now open to ALL Large Categories, but it says this in the draft “Instructions Applicable to All Offerors”
- Current FASt Lane eligibility requirements and participation standards will still apply to eligible FASt Lane participants
- FASt Lane modification processes will remain limited to the IT Category and will continue to apply only to designated FASt Lane-eligible initiatives
Here's what's changing:
- FASt Lane eligibility is opening up to all MAS Large Categories (for offers)
- For categories other than the IT Category, FASt Lane eligibility will apply to offers only (not modifications)
- Offerors outside the IT Category can seek FASt Lane consideration when a validated federal requirement is demonstrated through agency sponsorship or documented customer demand
One important note for anyone currently working on a FASt Lane submission: if you're eligible for FASt Lane but haven't submitted your offer yet, you'll need to initiate a new application through the eOffer portal to maintain your FASt Lane eligibility once Refresh #33 takes effect.
TAA Exemption Change for Federal Prison Industries and AbilityOne
Refresh #33 also implements Class Deviation CD-2026-03, which eliminates the Trade Agreements Act (TAA) exemption that previously applied to Federal Prison Industries, Inc. and AbilityOne Participating Nonprofit Agencies. If your offerings overlap either of these programs, this is a change worth flagging to your compliance team.
New Product Substitution Restriction
GSA is adding new language to the "General Information" section of each Large Category solicitation attachment that restricts product substitutions. The new requirement states:
"Product substitutions are prohibited without prior written consent from the buyer. All authorized substitutions must be listed on the MAS contract and priced no higher than the original item, except in cases where the customer explicitly approves a more expensive MAS-listed alternative."
In short, contractors won't be able to swap in a different product on an order without the buyer's written sign-off, and any approved substitute has to already be on your MAS contract and priced at or below the original item, unless the customer knowingly agrees to pay more.
Large Category and SIN-Specific Changes in Refresh #33
Beyond the Solicitation-wide updates, GSA is proposing changes to specific Large Categories, Subcategories, and Special Item Numbers (SINs). Here's what's included so far:
Facilities (B)
Within the Structures Subcategory (B06), GSA is proposing changes to two SINs:
- SIN 238160, Roofing Products and Services Solutions: The current description limits services to installation and site preparation "ordered in conjunction with" roofing products for repair or replacement of an existing roof. The proposed description makes it explicit that this SIN can be used to satisfy requirements for materials only, services/labor only, or a combination of both.
- SIN 532490P, Lease/Rental of Pre-Engineered/Prefabricated Buildings and Structures: GSA is broadening the description to explicitly cover pre-engineered, prefabricated, portable, mobile, modular, and tension fabric buildings and structures, including utility rooms in addition to the previously listed office buildings, restroom facilities, and temporary living quarters. New SIN instructions also clarify the scope of this SIN to include general temporary facility needs and formalizes that this SIN covers turnkey temporary facility solutions where the primary requirement is the lease/rental of covered structures.
- To support this, GSA is adding a new SIN subgroup, Turnkey Base Camp Facilities and Operational Support Products or Services, and modifying an existing subgroup to become Lease/Rental of Pre-Engineered/Prefabricated Restrooms, Showers, and Utility Rooms.
Miscellaneous (G)
Within the Complementary SINs Subcategory (G06), GSA is adding two new SIN notes:
- A note on the 4PL SIN's "General Requirements" section clarifying that while food and beverages remain out of scope for the MAS program overall, the unique requirements of the 4PL SIN permit the inclusion of bottled water.
- A note on SIN 238910, Installation and Site Preparation Services, clarifying that ancillary services, incidental products, and equipment rentals may only be ordered in conjunction with and in direct support of products or services purchased under the Federal Supply Schedule contract. Any incidental products offered under this SIN must be separately priced and directly support the awarded Installation and Site Preparation Services.
Travel (L)
Two changes are proposed within the Travel Large Category.
- SIN 531, Employee Relocation Solution (L01): GSA is revising the Statement of Work (SOW) guidelines, specifically updating the move management requirements to ensure compliance with current audit and payment standards for household goods relocation services found in FMR 102-118.
- SIN 561510, Travel Agent Services (L03): GSA is proposing a set of revisions to both the SOW and Price Proposal Template (PPT) under this SIN. The SOW changes are detailed, so they can be viewed on GSA’s significant changes document. On the PPT side, GSA is updating the instructions on the “Read Me” tab and adding a new eOffers tab for Travel Management Companies (TMCs) that want to be added to the Schedule. This new tab makes certain Ancillary CLINs mandatory, ensuring a standard set of services is available across all TMCs and aligning with support for GO.gov.
Next Steps for Your GSA Schedule
Once GSA finalizes and releases Refresh #33, you'll need to review and accept the Mass Modification within 90 days. To stay on top of future Solicitation Refreshes, keep checking our blog and our monthly newsletter. And if you'd like help managing your GSA Schedule or navigating the Mass Modification once it's released, one of our consultants would be happy to help.
