The government fiscal year (FY) 2026 may have just concluded last month; however, changes to the GSA Multiple Award Schedule (MAS) are not slowing down as FY2027 begins. In early October, GSA released MAS Solicitation Refresh #33 which included eligibility requirement updates for contractors and new offerors to participate in GSA’s FASt Lane program. Additionally, as of Refresh #33, GSA’s Startup Springboard program, which allows entities with less than two years of corporate experience to get on Schedule, is no longer limited to just offerors under the Information Technology (IT) Large Category.
All of these recent changes impact if and when newly formed Joint Ventures (JVs) are eligible to pursue a GSA Schedule contract. In this blog, we’ll break down the new the FASt Lane participation requirements, recent changes to instructions for preparing Joint Venture offers, and other notable updates to the MAS Program to prepare your offer or contract for FY2027.
What is a Solicitation Refresh?
To quickly recap, GSA periodically releases updates to the MAS Program through Solicitation Refreshes. Solicitation Refreshes contain updates to the structure of the MAS Program itself, such as adding or removing Special Item Numbers (SINs), and introducing, revising, or deleting offer preparation instructions and applicable GSA Acquisition Regulation (GSAR) or Federal Acquisition Regulation (FAR) regulations.
Solicitation Refreshes are issued as Mass Modifications through the Mass Modification system. Typically, contractors will need to accept a Mass Modification within 90 days of its release. All authorized negotiators holding signing authority for the contract will be notified via email that a new Mass Modification is available for review and completion in the Mass Mod system.
Next, let’s focus on a few updates that were released under Solicitation Refresh #33 that affect recently established Joint Ventures.
What is a Joint Venture?
A Joint Venture is an entity formed between two or more companies and is often a strategy utilized by businesses to combine resources and capabilities with other companies to pursue contract opportunities. JVs must be established via a formal written agreement; if applicable, the agreement will need to meet specific Small Business Administration (SBA) requirements. The JV entity is required to have its own System for Award Management (SAM) registration with a Unique Entity Identifier (UEI) and a Commercial And Government Entity (CAGE) code to submit a MAS proposal.
Contractors are limited to being part of three Federal Supply Schedule (FSS) contracts as a Joint Venture partner.
How Should You Approach Developing a Joint Venture MAS Offer?
Due to recent Solicitation changes, the method taken to develop a Joint Venture MAS offer depends on whether the JV entity itself has more than two years of corporate experience. The JV partners’ individual experience cannot count towards the requirement for an MAS offeror to be in business for at least two years. If your JV was recently established, your MAS offer may qualify for GSA’s Startup Springboard Program, assuming the JV meets the additional eligibility criteria to be a MAS offeror.
When Solicitation Refresh #31 was released in the spring, the Startup Springboard program became restricted to offerors pursuing SINs under the IT Large Category and who also met GSA’s FASt Lane program requirements (more on FASt Lane later). After Solicitation Refresh #33, the Startup Springboard option is no longer restricted to just IT offerors; any qualifying offeror, including JVs, under any Large Category can participate as long as they still qualify for FASt Lane.
Startup Springboard for JV Offers
GSA’s Startup Springboard program provides alternative options for entities without the standard required two years of corporate experience and financial documentation to become a MAS contractor. If a JV has been in business for more than two years but doesn’t quite have two years of experience providing their services or products yet, the company can still qualify for the Startup Springboard program (provided they meet the other requirements).
Since participation in Startup Springboard is tied directly to FASt Lane participation, let’s focus on the FASt Lane requirements new JVs looking to obtain a MAS contract will need to meet.
GSA’s FASt Lane Program Under Solicitation Refresh #33
GSA’s FASt Lane program is a MAS contract onboarding option that provides offerors and contractors with access to quicker processing times if their offer or contract modification request meets several strict eligibility criteria, including:
- Being a MAS offeror or existing contractor under any of the 12 Large Categories (expanded from just the IT Large Category as of Solicitation Refresh #33)
- Associated with a FASt Lane-eligible initiative (expanded from just IT-related initiatives as of Solicitation Refresh #33). Examples of FASt Lane-eligible initiatives:
- Technology and IT solutions initiatives
- Supply chain and logistics initiatives
- Other MAS initiatives, across any large category, as identified to GSA by the customer that may arise. If you’re a current contractor, only contract modification initiatives within the IT Large Category are eligible for FASt Lane.
- Have an agency request demonstrating a compelling need for your company to be on Schedule (agency written request contents clarified as of Solicitation Refresh #33)
Under Solicitation Refresh #33, GSA has clarified the items that need to be addressed in an agency’s written request and has provided a new sample template for offerors to use as a reference. The letter should include the following information:
- The written request must be from and signed by the ordering agency’s CO responsible for the procurement. The CO’s contact information needs to be included, as well.
- A description of the procurement and the specific SINs being used.
- The estimated date for issuing the Request for Quote (RFQ), Sources Sought or Request for Information (RFI), or agency provided timelines for nonpublished acquisition initiatives, and any available flexibility in that timeline.
- The offeror’s name that the agency wants to participate in the identified procurement. The letter should demonstrate the specific need for the offeror to be on Schedule to compete, such as specialized expertise, demonstrated past performance, or compelling circumstances.
In addition, FASt Lane offers or modification requests will need to include the FASt Lane Eligibility Checklist which collects information on the specific RFQ, RFI, or Sources Sought that corresponds to the initiative described in the agency’s sponsorship letter.
After offer submission, all authorized negotiators associated with your offer should monitor their emails closely for any communications from a GSA CO. For a FASt Lane offer, you will need to respond to any clarification requests within 24 hours, while FASt Lane modifications require a response within two hours.
Do all JV MAS Offers Need to Meet the Startup Springboard and FASt Lane Program Requirements?
JVs with more than two years of corporate experience don’t have to worry about meeting FASt Lane or Startup Springboard requirements. Also, it’s important to note that if your company or JV entity has been operational for more than two years, you are still eligible to participate in FASt Lane. All Startup Springboard offers must also be FASt Lane offers but not all FASt Lane offers need to be Startup Springboard offers.
However, there are several components of a JV MAS offer that differ when compared to a non-JV offer, regardless of if the offer is a Startup Springboard/FASt Lane offer or not. A non-exhaustive list of additional requirements for JV offers is included below:
- Completion of the JV Solicitation Attachment available for download from GSA’s MAS required templates webpage.
- Submission of the JV agreement and if applicable, the entity’s SBA approved mentor-protégé agreement and SBA approval letter.
- Two years of financial statements for the JV itself. Exception: financial statements of the JV partners would be sufficient for Startup Springboard offers in addition to any financial statements for the JV entity.
- In the offer’s technical section, the Corporate Experience Narrative must address the JV’s experience; the partners’ experience alone will not be accepted. Exception: the corporate experience of the JV partners can be included in the narrative for a Startup Springboard offer, in addition to any experience the JV itself holds.
Other Recent MAS Solicitation Changes
In addition to the JV- and FASt Lane-specific updates to the MAS program under Solicitation Refresh #33, this Refresh included a few other key compliance updates to be aware of for new offerors and current contractors alike as we begin FY2027.
For example, in all Large Category Attachments, GSA implemented clarification regarding product substitutions; substitutions are prohibited unless the purchaser has approved the substitution in writing and the replacement item is currently awarded on the contractor’s Schedule and not priced higher than the originally quoted item (unless approved).
Preparing for the Upcoming Solicitation Refresh #34
GSA already anticipates releasing MAS Solicitation Refresh #34 in November. Before the next Refresh release, it’s important to understand how Solicitation Refresh #33 as well as other recent Solicitation Refreshes may impact your current MAS contract or potential JV offer moving forward.
In Refresh #34, GSA plans to potentially remove the 20-year limitation on MAS contract duration, introduce a new GSAR clause regarding use of artificial intelligence (AI) in contract performance, and make several SIN-specific changes. Our consultants would be happy to help prepare your JV or non-JV MAS offer and navigate any necessary modifications to your contract or offer that are a result of new Solicitation changes in FY2027.
