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Tag: MAS Consolidated Schedule

FY26 NDAA Delivers a Turning Point for the GSA Price Reductions Clause

A provision in the proposed Fiscal Year 2026 National Defense Authorization Act (FY26 NDAA) signals another decisive step in GSA’s long-running effort to move away from the Price Reductions Clause (PRC) in the Multiple Award Schedule (MAS) program. The House has already passed the bill, and if enacted, it would further weaken a clause that contractors and GSA alike have long viewed as overly burdensome and a barrier to participation in the MAS marketplace. (JD Supra December 17, 2025)

How the Price Reductions Clause Has Worked

GSA uses the PRC to ensure MAS pricing remains fair and reasonable. Under this approach, contractors disclose their Most Favored Customer (MFC), negotiate a Basis of Award (BOA) customer or group, and agree to give MAS customers pricing that is equal to or better than the BOA. If a contractor later gives the BOA better pricing, the PRC requires that reduction to flow to all MAS customers. (ibid)

In practice, this structure has created significant compliance risk. A single commercial discount, sometimes granted by an individual salesperson, can trigger sweeping price reductions across the MAS contract. Contractors have long described the PRC as one of the most complex requirements in federal contracting. (ibid)

Why GSA Has Tried to Move Away From the PRC

GSA has increasingly acknowledged that the PRC discourages participation in the MAS program, particularly for small businesses. To reduce this burden, GSA introduced the Transactional Data Reporting (TDR) pilot in 2016. Under TDR, contractors no longer track BOA pricing or comply with the PRC. Instead, they report detailed sales and pricing data monthly, allowing GSA to assess price reasonableness through market data rather than rigid price controls. (ibid)

GSA has repeatedly asked Congress to clarify its authority to abandon the PRC, noting that MAS pricing requirements represent its most burdensome information collection and can slow the addition of new products and services agencies need. (ibid)

Why the PRC Has Persisted Until Now

The primary obstacle has been a longstanding disagreement between the GSA and its Office of Inspector General (OIG). The OIG has argued that federal law requires MAS contracts to result in the “lowest overall cost alternative,” effectively mandating the PRC. GSA has disagreed and has pushed Congress to replace that standard with a “best value” approach. (ibid)

What the FY26 NDAA Changes

Section 812 of the FY26 NDAA adopts GSA’s position by changing the statutory standard for MAS contracts under Title 10 from “lowest overall cost alternative” to “best value.” This change aligns MAS contracting with broader federal acquisition principles and removes a key statutory argument for retaining the PRC, at least for defense agencies. (ibid)

What This Means for Contractors

The shift to a “best value” standard strengthens GSA’s ability to fully retire the PRC and expand TDR across the MAS program. GSA has already announced plans to make TDR mandatory for all Special Item Numbers beginning in FY26 and has confirmed its intent to transition all Schedule contractors away from the PRC within the next year. (ibid)

Price will still matter, but GSA will likely rely on reported transactional data and market research rather than automatic price reductions. Contractors with legacy PRC-based contracts should evaluate whether transitioning to TDR makes operational sense and engage early with their contracting officers. Companies considering entry into the MAS program should prepare to demonstrate price reasonableness even under TDR, as GSA can still request supporting pricing data when needed. (ibid)

Looking Ahead

While the NDAA provision applies directly to Title 10 acquisitions, similar language exists in Title 41 for civilian agencies. Congress may ultimately align both statutes to avoid a split standard. As GSA continues this transition, contractors can expect reduced PRC-related audit exposure; however, new compliance expectations regarding data accuracy, pricing support, and documentation will take its place. The era of the Price Reductions Clause is not over yet, but FY26 brings it closer than ever to an end. (ibid)

Do you have questions about how your contract will meet the new guidelines if the Most Favored Customer rules change? Give us a call.

New Year, New Mass Mod

At the start of the new year, GSA plans to issue a Mass Modification that will update Schedule contracts to mirror the new consolidated Multiple Award Schedule (MAS) for products and services. The new Multiple Award schedule was released this past October 1st. (GSA Interact, November 25, 2019)

The single Schedule solicitation promotes a simplified format, terms, and conditions along with new categories and Special Item Numbers (SINs). The new Schedule should make it easier for contractors to offer products and services and for agencies to find them. (ibid)

When the Mass Mod is issued, all current Schedule holder’s terms and conditions will align with the new consolidated MAS. The new consolidated MAS solicitation and category attachments are posted on BETA.SAM.gov. Attachments incorporate additional instructions and requirements specific to each large category, subcategory, or SIN. The new consolidated MAS solicitation includes:

  • Solicitation
  • Available Offerings Summary Document
  • Regulations Incorporated by Reference

The Available Offerings and Requirements page on GSA.gov contains templates and attachments for the solicitation. Instructions for each template can be found on Beta.Sam.gov; however individual documents will be housed on GSA.gov. (ibid)

So what do you need to do go get ready? GSA recommends attending one of the following webinars:

Session One:

Date: Thursday, December 19, 2019

Time: 2:30 – 3:30 PM EST

Registration Link: can be found by clicking here.

Session Two:

Date: Thursday, January 9, 2020

Time: 3:00 – 4:00 PM EST

Registration Link: can be found by clicking here. (ibid)

Individuals unable to attend either of the two webinars can find recordings on Interact. In addition, there is an Overview of MAS Consolidation and Consolidated Solicitation Advance Notice training recordings which can be reviewed at any time.

To understand the New Offerings structure, individuals should review the solicitation to understand where specific offerings will fall under the new large categories, subcategories, and SINs. In addition, review of the advance notice for the release of the MAS solicitation, for an overview of clauses, available offerings, and a matrix of clauses included in MAS. (ibid)

GSA recommends questions be submitted to your assigned contracting officer (CO) or the Multiple Award Schedule Program Management Office (MAS PMO) at MA****@*sa.gov. (ibid)

Once in receipt of the upcoming Mass Mod, we recommend you review it immediately. Note any exceptions. When responding to the Mass Mod, contractors will be presented with each clause in the consolidated Schedule and may either accept the clause or request an exception. Each exception must include a written justification and be negotiated with the CO. (Contractors should not take exception to clauses that do not apply to them.)

All responses to the Mass Mod are due before July 31, 2020. Those not responding by the due date will find their offerings unavailable on GSA eTools. The contract number, period of performance, products, and services offered as well as the assigned CO will not change as a result of accepting the Mass Mod. (ibid)

Concerns about the Mass Mod and whether or how an exception might affect your current Schedule? Concerned with how to justify an exception? Give us a call.