With all the changes going on under the new administration, it’s about time for a GSA Multiple Award Schedule (MAS) Solicitation Refresh. Refresh #25 is anticipated to be released sometime in March 2025. We know your head may be spinning with all the updates, but it’s important you know what’s going on in this Refresh because there are parts that affect all contractors. Let’s review the upcoming Refresh so you are prepared when the Mass Modification is released.
Changes to the Overall MAS Solicitation
First, we’ll cover some updates to the overall solicitation that will impact all GSA Schedule contractors. GSA plans to add the following advisories to the ‘General Information’ Section of each Large Category :
- In accordance with Executive Order (EO) "Defending Women from gender ideology extremism and restoring biological truth to the federal government” agencies must end funding related to gender ideology. This means any products, services, or solutions that violate the provisions of this EO are excluded from MAS Program scope.
- Under EO 14148, “Initial Rescissions of Harmful Executive Orders and Actions”, the MAS Program is removing all references to non-statutory sustainability requirements, programs, and preferences from its Special Item Number (SIN) instructions and descriptions.
- In response to EO 14208, Ending Procurement and Forced Use of Paper Straws, any products or services that are related to paper straws are excluded from the scope of the MAS Program.
Clause and Provision Updates
GSA also plans to incorporate the following clause and provision updates, which align with the list above. It’s important to note that there may be a lag in the System for Award Management (SAM) for these changes. Contracting Officers may continue to require entities to complete representations based on provisions that are going to be added or taken away. Contractors aren’t required to make any edits in SAM at this time.
First, GSA will remove the clauses, as specified in CD-2025-04, Federal Acquisition Regulation (FAR) Class Deviation for Revoked Executive Order 11246 “Equal Employment Opportunity”. The following FAR clauses will be added as a result:
- FAR 52.212-3, Offeror Representations and Certifications Commercial Products and Commercial Services (MAY 2024) (DEVIATION FEB 2025)
- FAR 52.212-5, Contract Terms and Conditions Required to Implement Statutes or Executive Orders Commercial Products and Commercial Services (JAN 2025) (DEVIATION FEB 2025)
- FAR 52.222-9, Apprentices and Trainees (JUL 2005) (DEVIATION FEB 2025)
The following clauses will be deleted as a result of this change:
- 212-3 Offeror Representations and Certifications- Commercial Products and Commercial Services (FEB 2024)
- 212-5 Contract Terms and Conditions Required to Implement Statutes or Executive Orders- Commercial Products and Commercial Services (NOV 2024)
- 222-21 Prohibition of Segregated Facilities (APR 2015)
- 222-24 Preaward On-Site Equal Opportunity Compliance Evaluation (FEB 1999)
- 222-26 Equal Opportunity (SEP 2016)
- 222-27 Affirmative Action Compliance Requirements for Construction (APR 2015)
- 222-29 Notification of Visa Denial (APR 2015)
Next, GSA plans to incorporate the provision and clause updates as specified in CD-2025-05, FAR Class Deviation for Section 2 of Executive Order 14148, “Initial Rescissions of Harmful Executive Orders and Actions,” and Section 2 of Executive Order 14208, “Ending Procurement and Forced Use of Paper Straws.” The following clauses will be added:
- 212-3 Offeror Representations and Certifications Commercial Products and Commercial Services (MAY 2024) (DEVIATION FEB 2025)
- 212-5 Contract Terms and Conditions Required to Implement Statutes or Executive Orders Commercial Products and Commercial Services (JAN 2025) (DEVIATION FEB 2025)
- 223-1 Biobased Product Certification (MAY 2024) (DEVIATION FEB 2025)
- 223-2 Reporting of Biobased Products Under Service and Construction Contracts (MAY 2024) (DEVIATION FEB 2025)
- 223-10 Waste Reduction Program (MAY 2024) (DEVIATION FEB 2025)
- 223-23, Sustainable Prod
The following clauses will be deleted:
- 212-3 Offeror Representations and Certifications- Commercial Products and Commercial Services (FEB 2024)
- 212-5 Contract Terms and Conditions Required to Implement Statutes or Executive Orders- Commercial Products and Commercial Services (NOV 2024)
- 223-1 Biobased Product Certification (MAY 2024)
- 223-2 Reporting of Biobased Products Under Service and Construction Contracts (MAY 2024)
- 223-10 Waste Reduction Program (MAY 2024)
- 223-23 Sustainable Products and Services (MAY 2024)
- 223-19 Compliance with Environmental Management Systems (MAY 2011)
- 223-22, Public Disclosure of Greenhouse Gas Emissions and Reduction Goals Representation (DEC 2016)
Updates to Specific Large Categories and Special Item Numbers (SINs)
Solicitation Refresh #25 also includes updates to specific Large Categories and Special Item Numbers (SINs).
Facilities (B)
Under Large Category B, Facilities, there are a few changes to specific SINs:
- For SINs 561210FAC Facilities Maintenance and Management, 561730 Grounds Maintenance, and 326199 Waste and Recycling Containers and Receptacles - Outdoor and Indoor Use, GSA will delete redundant SIN instructions.
- GSA will also revise the description of SIN 334512 Total Solution Support Products for Facilities Management Systems to account for the removal of the Energy Savings Performance Contracts (ESPC) subgroup.
- GSA will delete a note from the SIN description of SIN 332321 Doors, Windows, Skylights, Panels, and Shutters to remove unnecessary reference to environmentally friendly product options.
- Lastly, GSA will revise SIN description of SIN 238160 Roofing Products and Services Solutions to remove unnecessary references to sustainable and energy solutions.
Furniture & Furnishings (C)
In the Furniture and Furnishings Category (C), GSA will delete the description note of SIN 321918PF Portable Flooring Solutions to remove redundant references. These references include: Products may be biodegradable or non-biodegradable and may meet the requirements of the Environmental Protection Agency's (EPA) Comprehensive Procurement Guidelines Program (for recycled content) or the U.S. Department of Agriculture BioPreferred Program (for biobased content).
Human Capital Category (D)
Under the Human Capital Category (D), GSA plans to update the description/instructions for SIN 541612HC Agency Human Capital Strategy, Policy and Operations to remove references to gender ideology related items and Diversity Equity Inclusion (DEI) related items.
Industrial Products and Services (E)
In the Industrial Products and Services (E) Large Category, GSA will make the following updates:
- Revise description of SIN 325320 Pest and Animal Control Products & Services to remove unnecessary references to environmentally sustainable methods.
- Revise description of SIN 332913 Plumbing Products and Bathroom Fixture Solutions to remove unnecessary note that references energy efficient product options.
- Remove instructions of SIN 332913 Plumbing Products and Bathroom Fixture Solutions to get rid of the WaterSense requirement per Class Deviation CD-2025-05.
Information Technology (F)
Under Large Category F, Information Technology, GSA will remove redundant references to statutory programs (i.e. ENERGY STAR) and the preference for Environmental Assessment Tool (EPEAT) programs from “Section I Instructions for all IT Offerors.”
Professional Services (H)
In the Professional Services (H) Category, GSA plans to:
- Revise instructions of the Environmental Services Subcategory (H02) to remove all unnecessary references to specific environmental services.
- Revise SIN 541620 Environmental Consulting Services description to remove unnecessary reference to specific environmental services and reference to a revoked Executive Order.
- Revise description of SIN 562910REM Environmental Remediation Services to remove an unnecessary description of reclamation services and an outdated reference to “Davis Bacon”.
- Revise SIN 562910RMI Environmental Remediation Services - Multiple Industries to correct a typographical error and remove an outdated reference to “Davis Bacon”.
- Edit SIN 562112 Hazardous Waste Disposal Services instructions to remove requirements for certain electronic recycling standards recommended by the Environmental Protection Agency (EPA).
- Revise SIN 541370GIS Geographic Information Systems (GIS) Services description to remove an unnecessary qualifier of the types of Geographic Information Services offered under the SIN.
Transportation and Logistics Services (K)
In this Large Category, GSA will:
- Revise instruction notes of SINs 336212 Trailers and Attachments & 3361V Vocational Vehicles to remove a non-statutory sustainability preference.
- Revise description of SINs 485 Ground Transportation and SIN 532111 Automotive equipment rental and leasing, Rental Supplemental Vehicle Program (RSVP) to remove reference to the SmartWay Program which is no longer required per Class Deviation CD-2025-05.
Accepting the Mass Modification and Adapting to Future GSA Updates
As mentioned before, GSA plans to release MAS Solicitation Refresh #25 sometime in March 2025. Once it’s released, contractors have 90 days to review and accept the modification(s) in the Mass Mod System. It’s important to remember that only authorized negotiators on your GSA Schedule can access this site and acknowledge the changes.
It’s safe to say there’s a lot going on, and you may not have all the resources to track down every piece of news or update. To stay updated on future Solicitation Refreshes, check out our blog and our monthly newsletter. If you need assistance managing your GSA Schedule such as accepting Mass Modifications, one of our consultants would be happy to help you.
