Skip to content Skip to left sidebar Skip to right sidebar Skip to footer

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.

A Technology “Schedule” in the making

The Small Business Research program is in place for companies to use to develop state-of-the-art technologies. GSA is working to build a contract, much like the GSA Schedule platform, to give agencies access to these technologies. The idea is to shorten the time between a prototype of a new technology and the time it takes to get it to government users. (Washington Technology October 28, 2022)

Federal users lose out on many technologies because they never advance to phase two of the program. According to Jim Ghiloni, acting innovation sector director and IDIQ labs group manager at the General Services Administration (GSA), phase three becomes a challenge because it requires agencies to fund further development work to take advantage of new technology. Ghiloni recently said GSA is working on a government-wide contract vehicle that gives agencies access to these emerging technologies. (ibid)

Ghiloni is working on the business case to present to GSA while market research is ongoing. A draft solicitation is expected in the spring of 2023. Ghiloni plans for the vehicle to be in place by the fall of 2023. (ibid)

The plan is for the contract to look a lot like the GSA Schedule program. Here’s how it would work:

  • Companies finish phase two of an SBIR contract with technology ready to sell
  • Submit a proposal to get a spot on the vehicle
  • Market technology to government agencies (ibid)

All SBIR contracts have three phases. The first phase is developing proof of concept. The second phase is ongoing research and development to prove the technology is commercially viable. Phases one and two of an SBIR contract are funded by the SBIR program. For a company to move to phase three, an agency buyer is needed to commercially develop the technology. To date, this has been difficult because there has not been a mechanism for agencies to use to fund the third phase. (ibid)

Ghiloni hopes to make it easy for agencies to start taking advantage of emerging technologies while at the same time, drawing new entrants to the government marketplace. (ibid)

Is your small business developing an emerging or new technology? Give us a call.

The SBA should focus on small businesses, not fraudulent businesses

Last week the small business community urged lawmakers to shrink administrative burdens complicating entry into the Small. Business Administration’s (SBA’s) 8(a) program.

This is timely as the Biden Administration has set a goal to bolster the share of federal contracts awarded to small disadvantaged businesses from 5% to 15% by 2025. A former SBA official suggests the SBA focus on expanding entry to the program for disadvantaged businesses and not spend time penalizing those who fraudulently attempt to gain entry. This will go a long way to help achieve the goals as set by the administration.

Jackie Robinson-Burnette, CEO of Senior Executive Strategic Solutions and a former SBA senior program executive said SBA should, “shift their focus to include every firm that is eligible'” for the 8(a) program. She mentioned that she served at the SBA, the SBA received over 2,000 applications a year and accepted only 300 participants. The Government Accountability Office believes steps were taken to address fraudulent applications to the 8(a) program. Unfortunately, there remains no official verification procedure. The Government Accountability Office did not take steps to improve oversight of the program, according to report filings.

Robinson-Burnette said, “right now, the focus is making sure they mitigate the risk of firms getting into the program that shouldn’t be in the program – focusing on the fraud – when really that’s 1% or 2% of firms that apply. The other 90-plus percent of firms are struggling to get in … because the SBA is focused on the wrong thing.”

In addition to misplaced focus, Rep. Kweisi Mfune (D-MD) said business owners have reported concerns with the length of the program and that it takes most firms multiple years to receive their first awards. Mfune said, “this hinders the development of program participants and raises the question of whether enterprises are ready for graduation when they exit the program.”

Darryl Hairston, the SBA’s former associate administrator of business development, said he submitted a proposal to redesign the 8(a) program a few years ago. Hairston took into account the complexities small businesses encounter in navigating the federal marketplace during their initial years in operation.

Hairston said, “one of the things that we talked about was that most firms coming into the program, who are truly eligible for the program, had little experience in the federal marketplace. The timeframe is highly dependent upon how successful you are coming into the program and how well you take off with the benefits that are available to you.”

Robinson-Burnette feels adding priority access for SDB mentors will increase successful outcomes. This will occur by shifting some of the SBA’s dependence from their assigned business opportunity and creating additional inroads to work opportunities. Mfume is considering meeting with the SBA administrator to figure out “what can be done in the time we have.”

Are you a small disadvantaged business or a business looking to work with one on an upcoming contract? Give us a call.

Acquisition of Professional Services is about to get a whole lot better

Sheri Meadema, acting assistant commissioner of GSA’s Office of Professional Services and Human Capital Categories recently explained the current focus of the Services Marketplace. The Information Technology Category and Professional Services and Human Capital Categories are teaming to align how they introduce contracts and tools to aid buyers as well as suppliers of services.(FAS office of Information Technology February 17, 2022)

Their three main goals:

  • Expand GSA’s contract offerings.
  • Refine FAS’s market research and buying tools.
  • Better the data and reporting systems used in support of the current acquisition programs. (ibid)

Meadema envisions a future with standardized engagement and solicitation processes regardless of the type of services provided. The priority is on using a consistent set of best practices and tools for IT and professional services for solicitations, evaluation, negotiations, awards, and contract management. (ibid)

Meadema wants an easier final outcome compared to open market procurements. Under the Services Marketplace, the next generation of contracts is being built. These contracts include the Services MAC, Polaris, and the follow-on to Alliant 2. Currently in progress are:

  • 8(a) STARS III Government wide Acquisition Contract – a small business set-aside, Beset-in-Class GWAC. The the 8(a) STARS III, federal agencies can access award-winning 8(a) firms for emerging technologies via an established contract vehicle. This saves not only time but also taxpayer monvery over open markets methods.
  • IT GWAC Polaris is in development. The RFP for the new Polaris small business IT contract is expected in February 2022. Once awarded, Polaris will enable federal agencies to set-aside IT task orders to small business, women-owned small business, service disable veteran-owned small businesses, and businesses located in HUBZones.
  • PSHC is working on a new Services Multi-Agency Contract to support procurement requirements for services. This comes as OASIS winds down in 2024.
  • Improvement of Multiple Award Schedule service offerings. Contractors with multiple contracts will consolidate down to one. This means fewer overall contracts for the acquisition workfovce and industry parnters to manage. Ultimately this will make is easier for agencies to find the vendors to meet their requirements.(ibid)

Meadeama says they have also started standardizing the scope review process. A digital tool/portal allows customers to submit their scope review requests. This streamlines tracking, management, and coordination across portfolios as well as creating a single customer experience. The discovery phase has started for an order management tool for all services task orders. This allows for better solicitation development, tracking, and task order management on GSA contracts. (ibid)

Questions about how this might affect a current GSA schedule contract or upcoming bid? Give us a call.

Are you a MAS contractor or want to be one?

GSA is working to make it easier for prospective and current Multiple Award Schedule contractors to work with them. They have recently launched a new and improved Vendor Support Center (VSC).

According to eBuy’s Senior Program Analyst Rich Carlson, “our goals for this website overhaul were three-fold. One, we wanted to modernize the bedrock technology and make security enhancements, which aligns with VSC with other websites we’ve updated like GSA Advantage!. Second, we prioritized improving the user experience. And third, we needed to make business process improvements so the website is easier to maintain.” (GSA Blog January 12, 2022)

For the VSC update, GSA went straight to industry. An RFI was released in November with site navigation, help desk availability, and plain language as the main areas of focus. Based on the information obtained from feedback the VSC is searchable content takes less time and is much easier to find. The dynamic search function allows users to see all content when a word or phrase is entered into the search box. (ibid)

Another benefit of the VSC update is the ease of finding help desk information. The home page contains three types of locators for users individual Procurement Contracting Officer (PCO), Administrative Contracting Officer (ACO), and Industrial Operations Analyst (IOA). (ibid)

VSC site navigation is organized by: “I Want a Contract,” “Managing my Contract,” and “Contract Sales.” In addition, the new page “MAS Project Center,” stores resources for all MAS special projects. (ibid)

GSA is continually looking for ways to improve the customer experience and make it easier to do business with them. The new VSC is located at vsc.gsa.gov/vsc/. (ibid)

Questions about the new VSC or how to get started on your journey to a contract with GSA? Give us a call.