As a Multiple Award Schedule (MAS) contractor, you’re probably aware that keeping up with GSA’s frequent updates to the program can be a challenge. In the last few months alone, GSA has released Solicitation Refreshes with updated guidance for offerors, a new catalog management system that’s still evolving, and a revised methodology for pricing analysis.
Understanding GSA’s MAS updates is important for successfully maintaining your MAS contract. In this blog, we’ll go over some of the latest GSA Schedule updates and how they impact you as a MAS contractor. Some of these updates only apply to specific categories of contracts, so make sure to take note of which updates are relevant to your contract.
Updates to the FAS Catalog Platform (FCP)
The FAS Catalog Platform (FCP), the new catalog management system for MAS contracts that replaces the Schedule Input Program (SIP), will be rolled out to more contractors early this year. With this anticipated full launch, the majority of contractors offering Commercial Off-the-Shelf (COTS) products will be eligible to use the FAS Catalog Platform. Exceptions include contractors using zonal pricing, BPA pricing, or the 4PL SIN, who will not transition to the FCP until the system can support those features.
GSA plans to move all contractors offering products to the FCP in Fiscal Year (FY) 2024. Contractors offering services can expect to transition to the FCP in FY2025. Once it’s your turn to move to the FCP, you’ll receive a 60-day notice via email. In addition to notifying you that your contract is eligible, this email will outline steps you’ll need to take prior to using the FCP.
To prepare COTS contractors for the full launch of the FCP, GSA has released a training video demonstrating how to use the Options and Accessories tools within the Catalog platform. Utilizing these tools can help contractors better represent their products on GSA Advantage!.
GSA has also announced the creation of the “Services Plus” file, an FCP template that will be compatible with eMod. This new user-friendly document will consolidate the catalog information currently found in the Services and Training and Language Services Price Proposal Templates (PPTs).
New Transactional Data Reporting (TDR) Requirements
If you’re a GSA contractor who reports sales through Transactional Data Reporting (TDR), this update is for you. GSA has introduced new TDR fields and data quality initiatives in an effort to improve the quality and usage of TDR data collected in the FAS Sales Reporting Portal (SRP).
GSA has added new controls in the SRP for TDR submissions that will enable real-time validation of your Manufacturer Name, Manufacturer Part Number, Unit of Measure, and Unit Price fields against your contract’s catalog.
In addition, the Federal Acquisition Service (FAS) plans to roll out recurring contractor feedback reports to give contractors a more holistic view of their TDR data quality performance. This initiative will start in Quarter 2 with a small group of contractors. The reports will include month-over-month summary statistics, rolling counts of issue-based flags, and a view of comparative data quality performance based on SRP data.
By Quarter 3, you’ll also have the option to report on four new TDR fields when reporting contract sales, in addition to the eleven elements for which TDR contractors currently provide monthly data. These four new optional TDR fields will include:
- Order Date
- Ship Date
- Zip Code Shipped To
- Federal Customer
These new fields are part of GSA’s effort to improve TDR data quality, paving the way for new MAS Special Item Numbers (SINs) to be added to the TDR pilot.
Updates to the Market Threshold Calculation for COTS Products
If you sell Commercial Off-the-Shelf (COTS) products, bear in mind that GSA has changed how they calculate the market threshold to determine fair and reasonable pricing for COTS products. The market threshold calculation is an especially important metric if you’re a TDR offeror, because GSA relies solely on market research when determining fair and reasonable pricing for TDR offerings during pricing negotiations.
The new market threshold calculation will:
- Weigh centricity, or the median price, more heavily, rather than just the lowest price
- Introduce a new inflation adjustment component to respond to market conditions
- Incorporate TDR data in the calculation when high quality, comparable data is available
- Incorporate Commercial Pricing data from major websites in the calculation
- Introduce demand-weighted ceilings, with more aggressive pricing targets for high-demand products
These changes mean that the pricing analysis for COTS products will be based on more accurate and relevant market data. As a result, contractors who are awaiting pricing review for their Schedule modifications can look forward to a more streamlined process, and government buyers can look forward to fairer and more realistic pricing.
EPA Temporary Moratorium Extended to December 31, 2024
GSA has extended the temporary moratorium on several limitations in certain Economic Price Adjustment (EPA) clauses from March 31, 2024 to December 31, 2024. The recent extension of the moratorium was issued to provide time for the publication of a final rule that will incorporate a new EPA clause into the MAS program.
Originally issued in 2022, this moratorium addressed global inflation by granting contractors more flexibility when increasing contract prices. The EPA policy moratorium applies to all GSA contractors, whether your contract’s awarded EPA Clause is 552-216-70 or I-FSS-969.
The extended moratorium will continue to:
- Relax time limitations on EPA increases
- Relax the limit on the number of EPA increases a contractor may request
- Allow a lower level of approval, to one level above the Contracting Officer, for price increases above the EPA clause ceiling
- Clarify that if a contractor has removed an item from their MAS contract, the Contracting Officer may add the same item back at a higher price if the higher price can be determined “fair and reasonable”
- Allow requests for EPA increases to be approved by the Contracting Officer, whether above or below the ceiling percentage established in the Solicitation
Thanks to this temporary policy, you can submit a price increase in the first year of your contract, you can exceed the limit of three price increases per year, and you don’t necessarily have to wait at least 30 days between each price increase. Even with this increased flexibility, your Contracting Officer still needs to approve any requested price increases.
Updates to the Joint Venture (JV) Solicitation Attachment
If you’re a Joint Venture (JV) looking to get a GSA Multiple Award Schedule (MAS), you’ll want to be aware of some changes made to the mandatory JV Solicitation Attachment. GSA released these updates with MAS Solicitation Refresh #18, one of two recent refreshes. Completion of the updated JV Solicitation Attachment is required for all Joint Ventures submitting a MAS offer.
You’ll find the following changes in the updated Attachment:
- All JVs are now required to disclose whether a JV partner is currently subject to an OIG audit.
- JV offerors representing themselves as a small or socioeconomic category are now required to acknowledge that they have completed FAR 52.212-3 dated December 2022 or later in SAM.gov.
- JV offerors representing themselves as a small or socioeconomic category are no longer required to complete their Small Business Program Representations in the JV attachment itself.
The JV Solicitation Attachment document was originally released in Solicitation Refresh #16, which provided much of the current guidance for Joint Ventures preparing MAS offers. This brings us to our final MAS update.
Required Modification for JV Contracts Awarded Prior to MAS Refresh #16
If you’re part of a Joint Venture holding a MAS contract awarded before May 19, 2023, you’re required to submit a contract modification to comply with the JV-specific requirements issued in Solicitation Refresh #16, per GSA’s recent mass modification A863. Released in May 2023, Refresh #16 provided key guidance for Joint Venture offerors, including how to align their MAS offer with Small Business Administration (SBA) standards.
Below are the documents you’ll need to include with your modification request in eMod:
- A JV Solicitation Attachment and all documents required by the Attachment (as applicable)
- A Price Proposal Template (PPT) that identifies which JV partner provides the awarded service, within the Labor Category/Service Title column
- A draft authorized FSS price list that includes the required JV information/disclosures as well as updated Labor Category and Service Descriptions
You’re required to submit this modification request before the release of the next MAS Solicitation Refresh, slated for Spring 2024. If you intend to submit other modification requests or are being evaluated for an upcoming option exercise prior to the new Refresh, you’ll need to first submit this conformance modification request.
Upcoming: Multiple Award Schedule Refresh #20
GSA recently announced GSA MAS Solicitation Refresh #20 which will be released sometime in April 2024. They will hold a webinar outlining the changes on April 1, 2024 but have released a draft of the significant changes. Routine updates include Price Proposal Template (PPT) edits, changes to specific Special Item Numbers (SINs) such as adding additional instructions and statements. Other updates include:
- Address the 12-month waiting period if contract is canceled/allowed to expire due to non-compliance
- COTS products are prohibited from being duplicated and published to GSA eLibrary text file
- COTS products should be published on GSA Advantage!
A full list of the drafted updates can be found on GSA's Interact post.
Keeping up with Future MAS Updates
Staying informed about MAS updates will help you maintain your contract more effectively, whether you’re seeking to increase prices, manage your catalog, or report sales. GSA is continually updating the MAS program as they find better ways of serving the government’s procurement needs, so these almost certainly won’t be the last updates you see on the FCP, JVs, or TDR, among other MAS topics.
If you’d like to keep up with future Schedule changes, we recommend subscribing to our blog and our monthly government contracting newsletter. And if you have specific questions on these updates or need assistance with preparing modifications for your GSA Schedule contract, our consultants are here to help you.
