The last nine months have been a flurry of Executive Orders (EOs), updates, and overall policy changes to the world of federal procurement. Many of these have impacted the GSA Multiple Award Schedule (MAS) Program and will continue to leave an impact on how contractors can do business with the government. We know it’s busy enough juggling your commercial business alongside holding a GSA Schedule, and you can’t always keep up with every change, especially if they are happening in rapid fire.
Since we are entering federal Fiscal Year 2026 on October 1, we want you to start your year off knowing how your contract is impacted and what changes we anticipate seeing in the near future. So, we’ll recap the important policies and updates to the MAS Program the last several months in case you missed them.
Multiple Award Schedule (MAS) Refreshes
To account for the many changes within the federal government, GSA has pushed out several MAS Solicitation Refreshes and subsequent Mass Modifications for contractors to accept. We’ll cover the latest ones below.
MAS Refreshes #27/#28
These Refreshes are really the same, #28 was just created to fix system errors in #27. So in Refresh #28, GSA made several changes including:
- Adjusting the Letter of Supply Requirement
- Adding more out of scope items
- Retiring 10 Special Item Numbers (SINs)
- Expanding Transactional Data Reporting (TDR)/making it mandatory for all eligible contractors
The Letter of Supply requirement was reduced to only resellers under Large Category F (Information Technology) and the Printing and Photographic Equipment Subcategory within Large Category A (Office Management).
- GSA’s out of scope additions in Refresh #28 are:
Fully assembled rotary-wing or fixed-wing aircraft - Books and publications (except technical publications and reports on SIN 511120)
- Children’s toys, dolls and games
- Promotional products
- Sporting goods
- General clothing items (except workwear under SIN 3152, uniforms under SIN 315210 and protective apparel under SIN 339113PA)
- Swimming pool equipment and supplies
- Musical instruments
- Customizable awards, medals and ribbons
GSA also retired 10 SINs in this Refresh, which are listed in our blog covering Refresh #28. We’ll dive more into the TDR changes below because there’s a lot to discuss around that update.
MAS Refresh #29
In MAS Refresh #29, GSA tied up a few loose ends from previous Refreshes and paved the way for future FAS Catalog Platform (FCP) transitions.
To prepare for the upcoming transition of all contractors into the FCP, GSA replaced the Price Proposal Templates (PPTs) with the FCP Product File and the FCP Services File. Not every contractor has begun or completed the FCP transition yet, but GSA is making plans for the full transition.
Also in Refresh #29, GSA consolidated the Economic Price Adjustment (EPA) clauses to make price changes more standard across the MAS Program. All of the legacy clauses will be replaced by a single clause, GSAR 552.238-210, Economic Price Adjustment Federal Supply Schedule (FSS) Contracts. This clause also keeps the temporary pricing flexibilities allowed during the pandemic and extended through September 30, 2025.
One of the other notable changes in Refresh #29 is officially retiring the 19 Small Business Set Aside (SBSA) SINs and removing them from the Solicitation. If you only hold a contract under an SBSA SIN and have no other MAS contract, you will need to establish a new contract number. GSA should have already been in contact with you on this migration.
Transactional Data Reporting (TDR) Expansion
As we mentioned above, GSA has made major strides in the Transactional Data Reporting Program (TDR). In Refresh #27/#28, GSA ended the TDR pilot and made it mandatory for all contractors who hold at lease one TDR SIN. GSA also expanded the eligible list of SINs to include ALL product SINs and the Cloud SIN. A full list of TDR eligible-SINs can be found on GSA’s site.
TDR is another form of sales reporting, differing from the legacy Commercial Sales Practices (CSP). Under TDR, you don’t need to disclose your Most Favored Customer (MFC) and you do not need to follow the Price Reduction Clause (PRC). You will however have to report your GSA Schedule sales monthly instead of quarterly, and report on 12 data elements (16 in total with the optional 4 elements released last year). To learn more about TDR and the transition, check out our recent webinar.
Order Level Materials (OLM) Special Item Number (SIN) Cap Removed
This is a new change that we have yet to see more info on, but GSA has removed the 33% cap on Order Level Materials (OLMs) in an order. OLMs are products or services added to the contract (at order level) that were not originally included in contract award. They are usually in the form of:
- Direct materials
- Subcontracts for supplies and incidental services for which there is not a labor category specified in your GSA Schedule contract
- Other Direct Costs (which we’ll discuss below)
- Indirect costs
There is now no mention of the 33% cap in the General Services Acquisition Manual (GSAM), but we still are waiting on more information and guidance on GSA for this change.
Revolutionary FAR Overhaul (RFO)
The White House has been working with the Office of Management and Budget (OMB) to rewrite the FAR to return it to its “statutory roots”. This revision is commonly referred to as the Revolutionary Federal Acquisition Regulation (FAR) Overhaul, or RFO. The idea set forth in EO 14275 is to revise the FAR so it only includes statutory requirements, consists of plain-written language, and emphasizes commercial buying more.
This revision will inevitably impact contractors within the MAS Program since the FAR is essentially the bible for federal government contracting. The hope is that Contracting Officers will be able to work quicker and without as much red tape, but there are concerns as to what impacts cutting out specific FAR language will have on certain acquisitions such as small business set-asides.
GSA Procurement Expansion
This Executive Order (EO) was released earlier in the year, but it has been the source of many changes within GSA. The Trump Administration wants to expand federal procurement under GSA, including transitioning the procurement of most common goods and services to GSA. GSA will also be managing larger Governmentwide Acquisition Contracts (GWACs) such as NASA SEWP VI and CIO-SP-4.
As GSA prepares for this transition, we can expect for award and modification timelines to be delayed, but in the future, we can anticipate a lot more business through the MAS Program and GSA GWACs.
What’s Next for the MAS Program?
We don’t anticipate any of these changes to slow down, so it’s important you are keeping track of how they may impact your contract and accepting the Mass Modifications by their due date.
To stay on top of future contracting news and insights, subscribe to our blog and monthly newsletter. If you need help managing your contract throughout all these updates, or you have questions about how the changes are affecting your company, we are here to help.
