As a result of the Trump Administration’s April 2025 Executive Order (EO) directing for the rewrite of the Federal Acquisition Regulation (FAR), the FAR Council initiated the Revolutionary FAR Overhaul (RFO) effort. The goal of the RFO is to ensure the FAR only contains statutory rules that enhance clarity, resulting in more efficient procurement processes. Federal agencies have been implementing rewritten FAR parts through their own class deviations.
We have previously discussed the FAR Part 8 overhaul, which transitioned most information regarding Federal Supply Schedule (FSS) ordering procedures from FAR Subpart 8.4 to the General Services Acquisition Regulation (GSAR) Subpart 538.71. In this blog, we will review the updated Multiple Award Schedule (MAS) ordering procedures under GSAR Subpart 538.71, including changes to establishing Blanket Purchase Agreements (BPAs), purchasing open market items, and contractor use of other MAS contracts to fulfill orders.
GSA’s Class Deviation RFO-2025-FSS-GSAR 538 implemented the FAR Council’s model deviation text for FAR Part 8 and established procedures for agencies to follow when placing orders and establishing BPAs under the FSS Program, including MAS, in GSAR Subpart 538.71. Prior to the RFO, FAR Subpart 8.4 outlined these processes; the overhauled FAR Subpart 8.4 now directs ordering agencies to GSAR Subpart 538.71.
GSAR Subpart 538.71 is an abbreviated version of the original FAR Subpart 8.4 text, with many provisions relating to MAS ordering procedures removed or revised to align with the RFO’s guidance of eliminating duplicative and non-statutory language. Now, let’s discuss these updated policies.
GSAR Subpart 538.7102-2 clarifies that ordering activities do not need to establish evaluation plans, score quotations, or competitive ranges prior to interacting with quoters or solicitating revised quotations. These processes are associated with FAR Part 15 (Contracting by Negotiation) and are not applicable to this subpart. Agencies are also encouraged to use “innovative approaches” when issuing Requests for Quotes (RFQs), which refers to techniques, automation tools, and other resources housed in the Periodic Table of Acquisition Innovations (PTAI) webpage. The “best value” evaluation criteria, as defined in FAR 2.101, is emphasized throughout this subpart, and references to “lowest overall cost alternative” have been removed.
Further, FAR Subpart 8.405-1, which addressed ordering procedures for supplies and services not requiring a statement of work, and FAR Subpart 8.405-2, which addressed ordering procedures for services requiring a statement of work, have been eliminated. Instead of two distinct provisions, GSAR Subpart 538.7103-2 includes a streamlined approach to releasing RFQs when a statement of work is required and when the product or service is clearly defined and available at a fixed price between the Micro-Purchase Threshold (MPT) and Simplified Acquisition Threshold (SAT).
For agencies establishing BPAs against a GSA Schedule contract, a few requirements have been updated to ensure clarity. The BPA must include sufficient details regarding the scope of work; ordering period; ordering activity requirements, such as invoicing, delivery, and discounts; ordering procedures; and any ordering limitations.
Ordering agencies must also verify annually and provide a written determination that the BPA still represents the best value, ordering procedures are being followed, whether estimated quantities or amounts have been reached or exceeded, if additional discounts are available, and that the MAS contract which the BPA was established against is still valid.
Additionally, a Head of Contracting Activity (HCA) is no longer required to approve single-award BPAs valued over $150 million.
Under the RFO, there is now streamlined guidance on how agencies should procure items not awarded to a FSS contract or BPA. Instead of relying on the open market item guidance of FAR Subparts 8.402(f) and 8.403(b), agencies are instructed to follow the ordering procedures under GSAR Subpart 538.71 for Order-Level Materials (OLMs).
For the MAS Program, contractors are likely familiar with the OLM Special Item Number (SIN). The OLM SIN allows contractors to add supplies or services at the task order level that were not originally awarded to their GSA Schedule contract. These items become part of your contract for the duration of a specific order to fulfill the buyer’s requirements. Under the RFO, OLMs are no longer required to be less than 33.33% of the total order, which expands the potential volume of OLMs that can be incorporated into an order. However, OLMs cannot be the primary purpose of the order and are considered incidental; this guidance applies to OLMs added to BPA orders as well.
OLMs are now allowed on all order types, including Firm-Fixed-Price (FFP), Time and Materials (T&M), and Labor Hour (LH) contracts. The ordering activity will evaluate contractors’ proposed pricing at the task order level to ensure the pricing offered is still fair and reasonable. Similarly, contractors should be aware that products and services offered through the OLM SIN are subject to the same restrictions that apply to contract-awarded supplies and services, such as compliance with the Trade Agreements Act (TAA).
If you are an existing contractor and do not currently have the OLM SIN awarded to your contract, you will have the opportunity to add this SIN to your contract through a one-time Mass Modification after GSA releases Solicitation Refresh #31 sometime in February 2026.
Per GSAR Subpart 538.7102-1(e), MAS contractors can purchase from other MAS contractors to complete an order. This capability allows contractors to source supplies or services from vendors that are already vetted by GSA, ultimately reducing supply chain risk and noncompliance with the MAS Solicitation or FAR requirements.
You are required to follow MAS ordering procedures described under GSAR Subpart 538.7103 and maintain detailed records of the ordering process, including the following documents: competition documentation or limited source justification, price reasonableness determinations, proof of compliance with MAS requirements, and quotes, communications, and award documents.
You would not report this purchase as a GSA sale or charge/remit the Industrial Funding Fee (IFF). The contractor you purchased from would track this purchase as a GSA sale, charge you the IFF, and remit the IFF. The price billed to the ordering agency should be the exact price you paid to the other MAS contractor.
You do not need authorization to purchase from another contractor’s Schedule to supplement your services; however, some agencies may not be aware of this feature. Thus, it’s a good idea to let the ordering activity know that you intend to purchase from another MAS contractor to fulfill an order requirement.
While the RFO may have resulted in several updates to MAS ordering procedures, several processes are maintained. Agencies are still directed to utilize small business set-asides to support the achievement of their small business subcontracting goals for the year.
Further, GSAR Subpart 538.7102-1(d) continues to allow for the use of Contractor Team Arrangements (CTAs). CTAs provide GSA Schedule contractors with the opportunity to establish a partnership through a written agreement, allowing the contractors to combine their awarded contract offerings to fulfill an agency’s order. GSA provides a template for CTA agreements on their website.
GSA has several online resources available to assist federal buyers and contractors in navigating the new MAS ordering procedures under the RFO. As a result of the RFO and updated MAS ordering procedures under GSAR Subpart 538.71, GSA Schedule contractors can expect increased usage of the OLM SIN. Considering the new and revised processes discussed throughout this blog, contractors have more flexibility and access to tools that agencies expect to be utilized to complete orders without relying on traditional open market items.
If you would like assistance understanding how MAS ordering procedures under the RFO impact your contract, our experienced consultants are available to support you.