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In their continuing effort to streamline certain antiquated aspects of the Multiple Award Schedule (MAS) Program, GSA updated the Economic Price Adjustment (EPA) clauses in MAS Refresh #29. Instead of the two main EPA clauses contractors used to calculate the increase of their prices, GSA consolidated them into one main clause. GSA also kept the same price flexibilities listed in the original March 2022 Acquisition Letter, which removed specific time-based limitation and ceiling percentage limits.
Contractors are actively working on accepting the Mass Modification for Refresh #29 and starting to implement the new EPA clause, but don’t worry if you’re a bit behind in the process. In this blog, we’ll cover how you can implement the new EPA clause in whatever stage you are from prospective contractor to seasoned MAS vendor.
What is the New Economic Price Adjustment Clause (EPA)?
Pricing in the MAS Program has traditionally been a bit of a process. When you are initially preparing your GSA Schedule offer, you must make sure your prices are “fair and reasonable” and represent best value. Although there is proposed legislation out there that is pushing a shift from lowest cost to best value (FoRGED and SPEED Acts), GSA still currently prioritizes lower prices to keep rates down. While we still have a ways to go on that legislation, GSA has been making strides in MAS processes, so they are more efficient and standardized. Hence the consolidated EPA clause.
EPA clause 552.238-120 replaces the two legacy clauses, I-FSS-969 and 552.216-70. I-FSS-969 was broken down into two parts (b1 and b2). All of the former EPA mechanisms and methods (which we’ll break down more below) remain the same, but you’ll just need to manually incorporate them into your offer or contract.
As mentioned above, the new clause does not include specific time-based limitations or ceiling percentage limits.
EPA Methods and Mechanisms
The EPA method is the agreed upon procedures that dictate how your price adjustment will be implemented over time. Methods include:
- Timing of increases
- Frequency of increases
- Any limits that may apply
- The mechanism
The EPA mechanism is what the clause is based on and is the tool or basis used to make the price adjustment. Mechanisms in the new EPA clause include:
- Adjustments based on fixed escalation rates
- Adjustments based on a market index or other basis
- Adjustment based on established pricing
- Pricing must be dated, existing, standalone, and not prepared solely for the government
*EPA modifications under fixed rate or Commercial Price List (CPL) mechanism do not need to determine fair and reasonable pricing.
How to Implement the New EPA Clause As an Offeror
If you are a new offeror, or you recently submitted your MAS offer, the new EPA clause still affects you. Here’s what you do depending on what part of the offer process you are currently in:
If you submitted your offer BEFORE MAS Refresh #29, your assigned Contracting Officer (CO) or Contracting Specialist (CS) will prompt you to accept the most current refresh and update your documents if needed. GSA is about to release Refresh #30 in November 2025, so you may be accepting a few Refreshes.
If you are submitting your offer AFTER Refresh #29, the solicitation will already contain the current requirements and guidance regarding the new EPA clause. You’ll just need to make sure you are providing the required info in the pricing terms section of the price proposal template before submitting your offer.
How to Implement the New EPA Clause with an Existing GSA Schedule
Implementing the new EPA Clause into your existing contract should be done soon if you haven’t already. Here’s what you need to know:
- First, you must accept Refresh #29, which removes the legacy clauses. You must do this by November 26, 2025.
- Next, you can submit a Revise Terms and Conditions (T&C) modification BEFORE a triggering event, such as:
- Submission of an EPA modification request: Any contractor request for an EPA-related pricing adjustment.
- Submission of any addition modification, such as add product, add labor category, add Special Item Number (SIN), etc.
- Option to renew contract: Exercise of option periods or option-related modifications.
- Then, you’ll incorporate the applicable EPA method and mechanism into your contract through the Revise T&C mod.
If you have a fixed escalation rate, the first option (submission of an EPA modification request: any contractor request for an EPA-related pricing adjustment) will not apply because your prices are set to rise automatically on your contract anniversary date. However, the other two options listed above could happen, and you must be prepared to submit a Revise T&C mod before the triggering event.
Are You Keeping Up With Your GSA Schedule?
The EPA clause consolidation is only one change that was announced this year in the MAS Program. Other updates include expanding Transactional Data Reporting (TDR) and preparing for the full transition to the FAS Catalog Platform (FCP).
If you want to be prepared for future GSA Schedule updates, you can subscribe to our blog and monthly government contracting insights newsletter. If you need help implementing the new EPA clause and other GSA Schedule maintenance tasks, or you are interested in getting a GSA Schedule contract, feel free to reach out to one of our consultants.
