We can finally say it's here--the Department of Defense (DoD) began implementing Cybersecurity Maturity Model Certification (CMMC) into solicitations and contracts last month. The DoD started with Phase 1, which covers Level 1 and Level 2 self-assessments. CMMC Level 2 and Level 3 assessments will be rolled out in subsequent phases.
If you haven’t already, now is the time to start prepping your company to handle CMMC requirements. As a reminder, CMMC currently applies to contractors in the Defense Industrial Base (DIB), who process, store, or transmit FCI or CUI. Once you determine the level of CMMC you need to reach (depending on your contracts or future contracts), you’ll want to assess your current cybersecurity measures and identify any gaps that need to be filled. Learn more about CMMC Phase 1 in our blog.
Are You Taking Advantage of National Stock Numbers (NSNs)?
If you work in the Defense Industrial Base (DIB), you may be missing out on key opportunities if you aren't familiar with National Stock Numbers (NSNs). If you want your products to be visible in defense and NATO procurement systems, they need to be tied to the right NSN. We are now offering NSN consulting and part number research to help contractor take advantage of NSNs. Learn more about our support here.
Cloud computing and software acquisition is a major topic for government agencies, and GSA wants to give small businesses the chance to learn how to become one of our Best-in-Class vendors to support various agency needs. Register here.
The MAS PMO hosts regular monthly office hours specifically for industry partners. These webinars cover different topics each month and this is your chance to get answers directly from MAS experts. December's topic will be announced soon.
CRITICAL INFORMATION
Refresh #30: Recent Changes and Updates
GSA recently released Solicitation Refresh #30, which includes several important changes. One highly significant change is the removal of Order Level Material (OLM) SIN regulations to align with updates implemented to the FAR as part of the Revolutionary FAR Overhaul (RFO). This greatly simplifies the requirements for OLMs to be added to an order, and removes the requirement that OLMs can only be 33% of an order’s total value. Additionally, the GSA notes that OLM subcategory limitations will remain in place through Refresh 30, but be removed in a future Refresh. Other updates included in Refresh 30 are the removal of the requirements for offerors to submit a Professional Compensation Plan and to provide evidence of an “uninterrupted source of supply”. Finally, the Pricing Terms template has been updated with additional fields related to the proposed Economic Price Adjustment mechanism. For more information, check out our blog.
QUICK TIP
How to Implement the New EPA Clause
As a GSA Schedule contractor, you have been able to increase your awarded pricing through the two Economic Price Adjustment (EPA) clauses (I-FSS-969 and 552.216-70). In Multiple Award Schedule (MAS) Refresh #29, GSA consolidated the EPA clauses into a single clause (552.238-120) in an effort to simplify and streamline the price adjustment process. While the EPA methods and mechanisms included in the original clauses remain the same in the new clause, contractors must still implement the new EPA clause through a contract modification as soon as possible. First, if you have not already, you must accept MAS Refresh #29 in the Mass Modification system. Since MAS Refresh #30 has now been released, you will have to accept this Refresh as well. Next, you should voluntarily submit a Revise Terms and Conditions (T&C) modification prior to one of the following triggering events, if applicable to your contract:
Submission of an EPA modification
Submission of an Additions modification, which includes adding Special Item Numbers (SINs), labor categories, products, etc. to your contract.
Exercising an option period or other option-related modifications.
The Revise T&C modification should include a cover letter signed by an authorized negotiator with the required EPA information as outlined in the MAS Modification Guide and your current awarded pricing document, which differs between contractors who use the FAS Catalog Platform (FCP) and those who use the Schedule Input Program (SIP) for catalog management. Review our recent blog for more information on the new EPA clause.
EMERGING BUSINESS OPPORTUNITIES
RFI: Configuration, Logistics, and Maintenance Resource Solutions (CLMRS) Information Technology (IT) Support Services for FAA ATO
The Federal Aviation Administration (FAA) has released a sources sought notice under NAICS Code 541512 (Computer Systems Design Services) to identify an experienced IT contractor that can provide technical development, integration, and support services to meet the evolving needs of the Air Traffic Organization (ATO) within the Configuration, Logistics and Maintenance Resources Solutions (CLMRS) team. Qualified vendors will work closely with the FAA to create a more agile, responsive, and efficient configuration, maintenance and logistics systems that support the agency’s strategic objectives and the evolving needs of its stakeholders. Vendors will also support the Supply Chain Management Enterprise Resource Planning (SCM-ERP) as well as other critical systems within the ATO. Responses are due by January 5, 2026. More information is available under Notice ID: 6973GH-26-R-01234.
Strategic Environmental Research and Development Program Core Broad Agency Announcement (BAA)
The Department of Defense (DoD) Strategic Environmental Research and Development Program (SERDP) has issued a pre-solitication under NAICS 541715 (Research and Development in the Physical, Engineering, and Life Sciences (except Nanotechnology and Biotechnology)) to identify parties interested in conducting research for Environmental Restoration, Resource Conservation and Resilience, and Weapons Systems and Platforms. Qualified parties will support SERDP’s environmental research by developing and applying innovative technologies and methods that enhance the Department of Defense’s environmental performance by improving outcomes, managing environmental risks, and reducing the cost or time required to resolve environmental challenges. Interested vendors must submit a pre-proposal in accordance with all instructions on the SERDP website by January 13, 2026. More information is available under Notice ID W912HQ26S0001.
FREQUENTLY ASKED QUESTIONS
Keeping your MAS contract compliant is a key duty for Schedule holders, but it’s also an easy thing to fall behind on. If you’re behind on contract compliance, here’s some frequently asked questions to help you catch up in the New Year.
Q: How Much Do I Need to Make in Sales?
A: GSA MAS does have a minimum sales requirement. Contractors must make $100,000 in sales in the first five years of the contract’s lifespan. The sales minimum increases to $125,000 in the next five years and stays at that threshold for the following two 5-year option periods. GSA doesn’t always cancel contracts that don’t meet the sales minimum, but this administration has placed an increased scrutiny on government efficiency and, with it, GSA has emphasized the importance of this sales minimum in keeping the MAS program running efficiently. It’s now more critical than ever that contractors are meeting that sales minimum.
Q: What Do I Need to Report for GSA Sales?
A: Reporting sales on time and correctly is a critical part of contract compliance. Contractors must report their sales in the Sales Reporting Portal by their assigned deadline. There are two types of reporting in MAS, Commercial Sales Practice (CSP), and Transactional Data Reporting (TDR). CSP contractors will report their sales quarterly, on the 30th of the month following quarter end, while TDR contractors will report on the 30th of each month for the month prior. Even if your contract is under CSP, that may be changing soon. GSA has announced that they will be moving all contracts to TDR sometime in the future, possibly as early as Q1 of 2026.
Q: How Do I Keep My Pricing Up to Date?
A: The prices on your GSA Schedule represent ceiling prices, so if you’d like to increase prices – for example, due to recent tariffs increasing raw material costs – then you’d need to submit an Economic Price Adjustment (EPA) modification. It’s important to know that your prices don’t automatically update after you submit that mod. Your Contracting Officer will have to review and approve that modification first, with possible clarifications and negotiations. After you’ve gotten your EPA modification approved, you’ll then need to update your prices in eLibrary and GSA Advantage!, either through SIP or FCP, depending on whether your contract has transitioned yet or not. Some contracts have a fixed escalation in place. In those cases, increasing prices does not require a modification. Rather, the prices will automatically increase at a set date each year, which is typically the anniversary of contract award.
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