There is a lot of research and paperwork involved with preparing an offer for the GSA Multiple Award Schedule (MAS) Program. A company’s MAS offer consists of an Administrative, Technical, and Pricing section. Our recent blog series broke down the requirements for each section of the proposal, but a frequent question we receive from our clients when developing the pricing section is how does GSA negotiate pricing?
The short, yet complex answer is that GSA’s requested discounts and pricing terms during the negotiations stage of the offer review process will vary between offerors and the types of products and services they are selling. GSA Contracting Officers (COs) and Contract Specialists (CSs) do not ask for a standard discount across all offers. However, CO/CS teams are required to evaluate all submitted price proposals for “fair and reasonable" pricing.
In this blog, we will break down GSA’s analysis of offerors’ proposed discounts and how the concept of “fair and reasonable” pricing affects this review. But first, let’s recap how to develop a discount for your proposed product or service offerings.
GSA released MAS Solicitation Refresh #31 in April 2026 which required all contractors and new offerors to participate in the Transactional Data Reporting (TDR) Program and removed the other sales reporting structure, Commercial Sales Practices (CSP), from MAS.
CSP required offerors with non-TDR Special Item Numbers (SINs) to disclose the discounts their commercial customers received within the previous 12-month period to identify the specific customer or customer group that received their best pricing, known as their Most Favored Customer (MFC). The discount your MFC received was used as a starting point for negotiations with your CO, as GSA wanted the same or a better discount than your MFC.
The removal of CSP is good news for offerors who often discount their commercial prices significantly for certain valuable customers, but it wouldn’t be sustainable to offer the same discounts to everyone.
While CSP and MFC pricing is no longer applicable to MAS, your price proposal under TDR should still model your commercial practices in the sense that your proposed products and services have been sold previously in the commercial sphere and are not new services or items that haven’t been developed yet. Now that TDR is mandatory for all offerors, you are not required to offer the same discounts that you do commercially, but GSA still expects a discount to be included with your proposal. Next, let’s discuss a few best practices for selecting a discount for your offerings.
First, you will need to decide on the commercial rates for your proposed offerings that will be disclosed in GSA’s required price proposal template. These are the rates that your discount percentage will be applied to. While TDR eliminates the requirement to submit pricing support with your offer, it’s a good idea to include supporting documentation with your proposal to validate your commercial rates as your CO/CS team has the authority to request pricing support to assist in their determination of “fair and reasonable” pricing (more on this later).
It’s important to note that contractors’ pricing is fully burdened, meaning rates include direct and indirect costs as well as profit. GSA-approved rates are ceiling rates, so you will have the opportunity to provide customers with additional discounts at the task order level to be competitive without affecting the awarded ceiling rate. For the initial offer’s negotiations stage, you will be reaching an agreement on the master contract level ceiling rates.
The key to developing a discount for your proposed MAS offerings under TDR is market research. Offerors can use several available GSA tools to compare their commercial pricing to direct competitors with GSA Schedule contracts and other existing contractors operating under the same or similar SINs to see how your pricing aligns in the federal space.
All MAS contractors have a dedicated page on GSA eLibrary, which contains the contract’s point of contact information, option period end date, socio-economic statuses, awarded SINs, terms and conditions, price list, and additional data. You can use the search function to find known competitors’ contract information page and download their awarded price list to evaluate their services pricing against your own.
For a broader search, GSA’s Contract-Awarded Labor Category (CALC) Tool is a searchable database containing contractors’ awarded fully burdened rates for labor categories across service-based SINs and can display search results via median and percentile or average and standard deviation options. The filter criteria (e.g., education, experience, SIN, etc.) support more refined search results.
Similar to other online marketplaces, GSA Advantage! is used by agencies to purchase contractors’ awarded products. This resource is a great tool to research various product types by entering general keywords (e.g., “tool kit”) or tailored product names (e.g., “Dell Latitude 5450 laptop”) into the search bar. The “Compare Sources” feature on a product’s page identifies whether the product is also sold by other contractors and the price points.
You have completed market research, proposed competitive rates to GSA, and submitted your proposal—now what? Your CO will reach out to schedule negotiations once all questions and inconsistencies have been addressed during the clarifications stage. Negotiations can occur via email or a phone/video call depending on the CO’s preference.
Before your GSA Schedule contract can be awarded, your CO must determine that the proposed prices for your products and services are “fair and reasonable.” Prior to negotiations, the CO/CS team will review your proposed pricing and decide if the pricing is “fair and reasonable” or if additional discounts are required. To assess an offerors’ pricing for price reasonableness, the CO will utilize existing sources of government data in accordance with Federal Acquisition Regulation (FAR) Subpart 15.4 (GSA Class Deviation RFO-2025-15) and GSAM 538.270-2, including prices paid for the same or similar items and contract-level prices on other MAS contracts for the same or similar items.
The CO may also conduct additional market research using CALC or GSA Advantage! or request additional pricing documentation from the offeror (e.g., invoices) if the previous resources listed are insufficient.
For Commercially Available Off-the-Shelf (COTS) items, the CO will evaluate proposed pricing using a market threshold algorithm that incorporates pricing data and trends from TDR reports, commercial catalog prices, and government contract prices from GSA Advantage!, FedMall, and NASA SEWP that will be included in a Compliance & Pricing (C&P) Report. The C&P Report identifies whether your products’ rates exceed their respective market thresholds. You may be required to lower COTS items’ pricing to be within the acceptable market threshold or provide supporting documentation to justify a higher price.
While contractors’ negotiations will differ depending on their unique offerings, the CO will likely ask for additional discounts or adjustments in the following areas:
You do not have to accept the initial discount requests from the CO; there will be some back and forth before an agreement is reached. Prior to negotiations, it’s important to have a good understanding of the maximum basic, prompt payment, and quantity/volume discounts that would be acceptable for your company.
By using GSA’s market research tools and factoring the results into your proposed discount(s), you can develop a pricing structure for your MAS offerings that supports GSA’s “fair and reasonable” pricing assessment. It’s the CO’s job to negotiate the best price for the government based on the products/services being proposed, and the CO will be reviewing other contractors’ pricing information to inform their requests for additional discounts.
If feasible, it’s a good idea to conduct a second round of market research prior to the negotiations meeting to see how your proposed pricing compares to current market data since there will be a waiting period between offer submission and GSA’s review of your proposed pricing.
Developing a discount for your MAS offerings and negotiating prices with GSA can be complex; if you would like assistance throughout the Schedule acquisition and proposal review process, reach out to our team and our consultants would be happy to support you.