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Contract management

This Refresh is MASsive

GSA recently announced the upcoming release of MAS Solicitation 47QSMD20R0001 – Refresh #27 via the GSA Interact community. GSA’s Federal Acquisition Service plans to issue the refresh in June 2025, with contractors required to accept the mass modification within 90 days of issuance. (BUY.GSA.GOV June 9, 2025)

Key changes in Refresh #27 include:

General Solicitation Updates:

  • Added sections for revoked Executive Orders and the EO on Ending Radical and Wasteful Government DEI Programs
  • Revised the “General Out of Scope Items” section
  • Updated instructions in SCP-FSS-001 for all offerors
  • Retired 10 SINs (see Significant Changes document)
  • Expanded the Transactional Data Reporting (TDR) pilot to 62 more SINs and make TDR mandatory for all Product SINs and Cloud SIN 518210C
  • Incorporate updated Service Contract Labor Standards (SCLS) Wage Determinations
  • Limited requirement for resellers to provide a Letter of Supply to items proposed under IT (Category F) and Printing/Photographic Equipment (A10, Category A)
  • Clarified base/accessory item proposal rules
  • Apply minor updates to the Price Proposal Template for Products
  • Incorporate clause/provision updates through FAC 2025-04 and GSAR Change 199 (excluding Change 187) (ibid)

Category-Specific Revisions:

  • Office Management (A): Updated SIN 511120 and removed Media Products Subcategory (A06)
  • Facilities (B): Revised SINs under Maintenance (B01), revisions to SIN 561210FAC and Supplies (B04): Revisions to SIN 322291 Restroom products
  • Furniture (C): Revised SINs in Packaged Furniture (C07): SIN 33721P and Fitness (C09): SIN 339920S
  • Miscellaneous (G): Revised SINs for Flags, Banners, Pennants and Related Products 33999F, Subcategory (G02):, Apparel Subcategory (G05): SIN 3152, Clothing and SIN 339113PA Protective Apparel, and 4PL Services (G06)
  • Travel (L): Updated SIN 531 under Employee Relocation (L01) (ibid)

⚠️ The Mass Mods Portal will be offline the weekend of June 28th for maintenance. (ibid)

Have questions about the refresh or acceptance instructions? Give us a call.

Trump Administration Moves to Overhaul Federal Procurement Rules

On April 15, 2025, President Trump signed two executive orders (EOs) aimed at transforming federal procurement. These actions directly impact contractors by pushing the system toward commercial solutions and simplified regulations. Insidegovernmentcontracts.com April 16, 2025

EO #1: “Restoring Common Sense to Federal Procurement” (FAR Reform EO)

This EO directs the Office of Federal Procurement Policy and the FAR Council to revise the Federal Acquisition Regulation (FAR) to include only what statutes require or what’s essential to sound procurement. Agencies must:

  • Appoint senior officials by April 30 to align their procurement rules.
  • Follow interim deviations and guidance ahead of final FAR amendments.
  • Prepare for potential “sunset” of non-statutory FAR clauses after four years unless renewed. (ibid)

OMB will issue implementation guidance by May 5 and enforce a “ten-for-one” rule—repealing 10 regulations for every new one added.

EO #2: “Ensuring Commercial, Cost-Effective Solutions in Federal Contracts” (Commercial Solutions EO)

This order requires agencies to prioritize commercial products and services under the Federal Acquisition Streamlining Act (FASA). Contracting officers must:

  • Justify any pending non-commercial procurements by June 14.
  • Submit their justifications for senior procurement executive (SPE) review within 30 days.
  • Obtain SPE approval for any future non-commercial contracts, with market research, price analysis, and rationale. (ibid)

Agencies must report progress to OMB within 120 days and annually thereafter, detailing compliance with FASA and progress on implementing the Order’s commerciality preference. (ibid)

What Contractors Should Do

  • Expect regulatory shifts that may change compliance obligations mid-contract.
  • Review current proposals to identify where you can frame your offering as a commercial item.
  • Engage proactively with contracting officers to support market-based solutions and pricing.

These changes aim to streamline procurement, reduce regulation, and shift focus toward cost-effective, commercially available solutions. (ibid)

Not certain how to frame your product/service as commercially available? Give us a call.

New Leadership for GSA

The White House has appointed new leadership to the General Services Administration (GSA), drawing heavily from the tech and finance sectors. On day one of the Trump administration, GSA welcomed its new team, including Stephen Ehikian as deputy administrator and acting administrator. (Federal News Network January 20, 2025)

Larry Allen, a longtime GSA expert, will become the associate administrator of the Office of Governmentwide Policy. Ehikian also introduced key political appointments: Josh Gruenbaum as commissioner of the Federal Acquisition Service, Mike Peters as commissioner of the Public Building Service, and Thomas Shedd as director of the Technology Transformation Service and deputy FAS commissioner. (ibid)

In an email message, Ehikian emphasized the GSA’s recommitment to its founding purpose of ensuring governmentwide efficiency and maximizing taxpayer value. “I recognize the critical importance of our agency’s mission and look forward to working together in the coming weeks to achieve it,” he stated. (ibid)

Ehikian outlined six guiding principles for the GSA:

  • Foster a culture of performance and accountability across federal government operations.
  • Eliminate waste, fraud, and abuse across the federal budget and processes.
  • Leverage best-in-class technologies to accelerate digital transformation and modernize IT infrastructure.
  • Uphold competitive principles that strengthen America’s economy, including fair and merit-based contract awards.
  • Promote “Made in America” policies to support domestic jobs and businesses.
  • Improve transparency, accountability, and collaboration within the GSA and with external partners. (ibid)

In a separate message, Ehikian detailed the agency’s future direction. He highlighted the GSA’s traditional role as a model of efficiency and pledged to refocus on streamlining government operations. “We will prioritize smarter, faster government services over larger, slower systems,” he explained. Ehikian also committed to aligning GSA priorities with the Trump administration’s objectives, such as:

  • Relocating federal operations from Washington, D.C., to regional facilities to boost economic opportunities nationwide.
  • Transitioning federal employees back to office environments to improve collaboration and accountability.
  • Supporting American innovation and removing ideological mandates, such as Green New Deal and ESG requirements, from construction and procurement policies.
  • Right-sizing the federal office portfolio by disposing of underutilized buildings and improving operational efficiency.
  • Enhancing transparency, accountability, and partnerships across government and industry. (ibid)

Ehikian acknowledged the dedication of GSA employees, attributing the agency’s transformation to their expertise and hard work. He announced plans for a new performance-based reward structure to align employee incentives with the agency’s mission. (ibid)

Ehikian brings extensive private-sector experience to his role, including positions at Salesforce and co-founding Airkit.ai, which Salesforce acquired in 2023. He also led RelateIQ, sold to Salesforce in 2014 for $390 million. Ehikian earned an MBA from Stanford and degrees in mechanical engineering and economics from Yale. (ibid)

Josh Gruenbaum, the new commissioner of FAS, joins GSA after serving as a director at the global investment firm KKR. This marks his first public-sector role following private-sector experience since graduating from NYU with dual MBA and JD degrees. (ibid)

Additionally, Ehikian named Frank Schuler and Michael Lynch as senior advisors in the administrator’s office and appointed Rusty McGranahan as general counsel. (ibid)

Questions concerning the changes at GSA and how your contract might be affected? Give us a call.

Don’t lose your Federal Government business – add a backup

The days are getting shorter, and surprises lurk in the night. Don’t let missing your entity registration renewal stop you from doing business with the federal government—that’s scarier than anything else!(Buy.GSA.GOV October 10, 2024)

Here’s some good news: your current Entity Administrator can add one or more backup Entity Administrators today. They simply log in, choose trustworthy team members, and invite them to join as Entity Administrators. No tricks, no complicated approval process. The new admins will have the same permissions, so make sure they’re a good fit! If they need guidance, we’ve got easy-to-follow instructions ready.(ibid)

Don’t wait until the last minute—ask your current Entity Administrator to invite backups now. With extra admins in place, you’ll always have someone ready to renew your registration on time and keep business with the federal government running smoothly. (ibid)

Need some help adding additional Entity Administrators? Give us a call.

2025 minimum wage is set, mostly

The Labor Department recently set new minimum wages for federal contractors, ranging from $9.30 per hour for tipped workers to $17.75 per hour, depending on job type. A pair of notices from the Federal Register lays out the specifics. Starting next January, federal contractors with agreements signed, renewed, or extended after January 2022 must receive a minimum wage of $17.75 per hour, regardless of whether they receive tips. This move stems from a 2021 executive order by President Biden, which expanded his $15 minimum wage mandate to federal contractors and required annual updates based on the Bureau of Labor Statistics’ Consumer Price Index (CPI-W). (Government Executive October 3, 2024)

For contracts signed before January 2022, the minimum wage for non-tipped workers will rise from $12.90 to $13.30 per hour, and tipped workers will see an increase in their “cash wage” from $9.05 to $9.30 per hour. Although this dual system is complex, Labor officials expect all contracts to soon fall under the new executive order, streamlining wage regulations. (ibid)

Despite the complexity of this dual wage system, Labor Department officials expect that soon all federal contracts will fall under the new executive order, eliminating the need for the older wage structure. (ibid)

Have questions about which minimum wage structure your contracts are covered under? Give us a call.