The Multiple Award Schedule Refresh #5 - What Contractors Need to Know

[This article was last updated on November 10, 2020]

Just as GSA contractors thought the updates were slowing down in frequency, the General Services Administration (GSA) Federal Acquisition Service (FAS) issued the Multiple Award Schedule (MAS) Solicitation 47QSMD20R0001 - Refresh # 5 on November 9, 2020.

This Solicitation Refresh will be accompanied by a Mass Modification (Mass Mod) for all current GSA Schedule contractors. GSA contractors will have 90 days to accept the Mass Mod after it has been issued. Solicitation Refreshes and Mass Modifications can be dense and difficult to understand, so let’s break down what the significant changes are for this MAS Refresh and Mass Modification and what that means for you as a contractor.

What Are the Major Changes in the MAS Solicitation Refresh #0005?

There are three significant changes that will be incorporated through this MAS Solicitation Refresh contractors should be aware of.

1. Incorporate the New Section 889 “Part B” Representation Requirement in the System for Award Management (SAM)

Section 889 Part B was incorporated into the MAS Solicitation through the last Mass Mod/Solicitation Refresh, which essentially restricts contractors’ usage of certain telecommunications and video surveillance equipment or services. You can learn more about Section 889 Part B in our previous blog.

This Solicitation update takes this incorporation to the next logical step and confirms contractors will accept the Section 889 Part B representation in SAM.gov. This representation in SAM requires entities to represent, based on a reasonable inquiry, whether they do or do not “use covered telecommunications equipment or services, or use any equipment, system, or service that uses covered telecommunications equipment or services.”

Starting October 26, 2020, offerors will not be required to respond to FAR 52.204-24 in solicitations if the offeror has responded to the SAM representation provision at FAR 52.204-26 that it both:

• “Does not” provide covered telecommunications equipment or services to the Government (e.g., the “Part A” representation) and,
• Based on a reasonable inquiry, “does not” use covered telecommunications equipment or services (e.g., the “Part B” representation).

2. Remove GSAR 552.204-70 Prohibition on Contracting for Certain Telecommunications and Video Surveillance Services or Equipment

This clause is being removed from the MAS Solicitation primarily because the requirements contained in the clause at GSAR 552.204-70 are no longer needed as the provision at FAR 52.204-26, created via FAR Case 2018-017, which was published on December 13, 2019, achieves the same purpose.

3. Update Vendor Templates for Agent Authorization Letter and Request to Hold Continuous Contracts

Contractors who have third party agents on their contract as authorized negotiators such as GSA Schedule consultants, are most likely familiar with the Agent Authorization Letter. This letter authorizes individuals who are not employees of your company, to speak, sign, and submit contract actions on your company’s behalf with GSA. In the updated Agent Authorization Letter, contractors are required to sign the completed letter using a digital signature.

In the new ‘Request to Hold Continuous Contracts’ template, contractors will be required to:

1. Identify any MAS contracts that are scheduled for, or are being audited, by the GSA Office of Inspector General.
2. Acknowledge they can meet all contractual requirements under both contracts.
3. Acknowledge their FSS pricelist on GSA Advantage! for the non-surviving MAS contract must be updated with 30 calendar days of contract award to include the following statement:

“[Non-Surviving Contract number] is listed here for reference purposes only and is replaced by [Follow on/Surviving Contract number]. [Non-Surviving Contract number] is only to be used for BPAs and orders awarded prior to or pending an award decision as of [follow on contract award/Surviving MAS mod date]. All new BPAs and orders MUST be awarded against the contractor’s new MAS contract [Follow on/Surviving Contract number].”

The updated version of the "Request to Hold Continuous Contracts’" will also be used by contractors submitting a MAS Consolidation Phase 3 “Add SIN” modification request to consolidate individual Non-Surviving MAS contracts to a Surviving MAS contract in accordance with the modification guidance posted on the GSA.gov page.

Contractors should note that these templates are not yet in place until MAS Solicitation Refresh #0005 is officially released. They should not be included in offers or modifications until the Refresh is released onto beta.sam.gov.

Are There Any Other Changes to the MAS Solicitation?

Other than the outlined changes stated above, there are some more changes happening through the new refresh on a Large Category specific level.

Large Category H – Professional Services will see two primary changes: Seven new Special Item Numbers (SINs) added and two existing SIN descriptions updated through the refresh. The SIN changes are highlighted below:

Added Special Item Numbers (SINs) to Large Category H – Professional Services

• SIN 562910RMI- Environmental Remediation Services – Multiple Industries
• SIN 541330EMI - Engineering Services Related to Military, Aerospace Equipment, or Military Weapons, the National Energy Policy Act of 1992, Marine Engineering and/or Naval Architecture
• SIN 541715AIR - Engineering Research and Development for Aircraft, Aircraft Engine and Engine Parts
• SIN 541715APM -Engineering Research and Development for: Other Aircraft Parts and Auxiliary Equipment, Guided Missiles and Space Vehicles, Their Propulsion Units and Propulsion Parts
• SIN 541713 -Research and Development in Nanotechnology
• SIN 541714 - Research and Development in Biotechnology (except Nanobiotechnology)
• SIN 541720 - Research and Development in the Social Sciences and Humanities

Updated SIN Descriptions

• SIN 541690 will be changed from:
  • “Integrated Logistics Support-Services include providing advice and assistance to businesses and other organizations on scientific and technical issues (except environmental). Typical associated tasks include, but are not limited to ergonomic/human performance analysis, feasibility analysis, logistics planning, requirements determination, policy standards/procedures development, conducting research studies, long-term reliability and maintainability, training, consulting, conduct acceptance, functional and post acceptance testing, testing, integration of the payload for flight Customer Agency, support provided during launch, orbital maneuvering and satellite separation from the spacecraft. Example: The full range of life cycle logistics support for the navigation satellite will be identified and designed in this stage including training, operation and maintenance requirements, and replacement procedures. An implementation guide for Space launch Integration Services (SLIS) can be found at www.gsa.gov/psschedule - click on Professional Engineering Solutions. NOTE: Services under this NAICs can not include architect-engineer services as defined in the Brooks Act and FAR Part 2 or construction services as defined in the Federal Acquisition Regulation Part 36 and Part 2.”
  • TO: “Technical Consulting Services - Services include providing advice and assistance on technical domains and issues not covered by any other subcategories or SINs on this Schedule. Typical associated tasks include, but are not limited to: strategic planning, feasibility analysis, requirements determination, policy interpretation and support, process analysis and/or development, research studies, testing (other than laboratory testing), and program analysis.”
• SIN 562910REM will be revised to better differentiate the SIN from SIN 562910RMI.

MAS Modification Guidance Update

The MAS Modification Guidance has also been updated to include streamlined procedures for adding SINs in Phase 3 of the MAS Consolidation. The Guidance and modification Price Proposal Templates (different from the offer Price Proposal Templates), are available in the MAS Modification Guidance on GSA.gov. If you need to modify your contract, use this guide to help you prepare your modification request. 

GSA created the MAS Modification Guidance as a consistent document to reference for consolidated MAS contracts. If you haven't reviewed the guide yet, we suggest you do, so you can successfully prepare and submit modification requests to your Contracting Officer. 

What Do Contractors Need to Do to Accept the Mass Mod?

Once you have a good understanding of the main changes that the Solicitation Refresh incorporates into your MAS contract, you will need to go into the Mass Mod system and accept it. Contractors will have 90 days to accept the Mass Mod. Contractors will receive an email letting them know of its release, but it’s important to remember that contractors no longer receive a PIN with the Mass Mod email.

Due to the recent implementation of the GSA FAS ID to the Mass Mod System, only authorized negotiators on the contract will be able to sign the Mass Mod and users will need to have an established GSA FAS ID to access the system. If you need to add any individuals with signatory authority, be sure to understand the modification process in the eMod system.

How Can You Stay Up to Date on Mass Mods and MAS Refreshes?

With so many updates in the world of MAS contracts, we at Winvale would highly recommend staying as up to date as possible with all the changes in order to remain compliant. For this Solicitation Refresh, be sure to check out this GSA Interact Post with specifics on the upcoming changes to the MAS Solicitation. For all things compliance and GSA news, be sure to subscribe to the Winvale blog to ensure you get all of the relevant GSA information that you need for your contract!