As a new or seasoned federal government contractor, you’re probably no stranger to adapting to frequent changes in policy and requirements. There have been a lot of changes to the Multiple Award Schedule (MAS) Program recently, especially through the Revolutionary Federal Acquisition Regulation Overhaul (RFO). One of these changes is to Order Level Materials, or OLMs. Read on to learn more about what an OLM is, how the RFO impacts OLMs, and how you can utilize the OLM Special Item Number (SIN) with these changes.
First off, let’s explain what Order-Level Materials (OLMs) are so you know what we’re talking about in terms of your MAS contract. OLMs are supplies and services acquired at the order level to directly support an individual task or delivery order under a Federal Supply Schedule (FSS) contract or Blanket Purchase Agreement (BPA).
Unlike other items listed on your GSA Schedule, OLMs are not initially included in your Schedule contract pricelist. They are added at the task order level when specific materials or services are needed, not at the time of your MAS award. OLMs exist so GSA contractors have more flexibility with their Schedules. For example, with an IT project, you may need specialized hardware, software licenses, or cables required from you or subcontractors that were not known or identified at the time of your contract award.
Pricing is evaluated by the ordering activity/Contracting Officer. In the past, OLMs in task orders could not exceed 33.33 %. This has changed with recent updates, which we’ll review below.
As mentioned above, the 33% cap on OLMs was removed under the RFO. This means that there is no longer a percentage limitation on OLMs in a task order, but they still can’t be the primary purpose of the order.
In MAS Solicitation Refresh #31, GSA is making it easier for contractors to use OLMs in the future by removing the subcategory limitation, so the OLM SIN be used like any other SIN in the MAS Program. All current MAS contractors who do not yet have the OLM SIN on their contract will be offered a one-time Mass Modification to add the OLM SIN.
Additionally, GSAR 538.71 is now the place contractors and buyers are directed to for MAS ordering procedures, which was previously FAR 8.4. Ordering activities must follow the procedures in GSAR 538.71 for OLMs as well.
When Refresh #31 is released, which we anticipate being sometime in February 2026, you will be given the opportunity to add the OLM SIN if you don’t have it yet. All current contractors will be offered a one-time Mass Modification to add the SIN, and if you’re a new awardee, a Mass Modification will be issued to you as well.
However, it’s important to note here that the Revolutionary Federal Acquisition Regulation (FAR) Overhaul, or RFO, has altered the way in which “open market items” are allowed within the MAS Program. There is now a more structured, OLM-SIN–based approach, meaning items that were once accepted as general “open market” additions must now meet the specific OLM requirements outlined in GSAR 538.71 (GSA Class Deviation RFO-2025-GSAR 538) and GSAR 538.72.
As mentioned above, ordering procedures for OLMs are outlined in GSAR 538.71. OLMs may be added to any order-type, i.e., Firm Fixed-Price, Time & Materials (T&M), or Labor Hour, as long as OLMs are clearly identified in the order. Pricing is set at the order level and it’s up to the ordering activity/Contracting Officer to ensure pricing is fair and reasonable.
OLMs can be added to Blanket Purchase Agreement (BPA) orders if:
One thing you may not be aware of (although it’s not a new concept) is being able to purchase from other MAS contractors to fulfill complex order requirements. MAS contractors are encouraged to use existing contracts when possible for OLMS, including other MAS contractors to acquire necessary products and services before going to open market items. Right now, you should continue to use open market items where required or necessary, but once the OLM SIN has been officially added, the requirement will change.
With all the new changes to the MAS Program and federal contracting as a whole, it’s important you are keeping up with everything related to your contract. If you have any questions about Refresh #31 and any future changes to your MAS contract, check out our weekly blog updates and monthly newsletter. If you have any questions about the OLM SIN or if you need help managing your GSA Schedule during Refresh #31 and any future Refreshes, we are here to help you.