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Contract management

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.

GSA Drops a Game-Changing MAS Refresh: Are You Ready for #30?

The General Services Administration (GSA) has announced a major update to the Multiple Award Schedule (MAS) program—and it’s more than a routine refresh. On October 17, 2025, the Federal Acquisition Service (FAS) revealed that Refresh #30 will land sometime in November. Contractors had until October 31 to submit feedback, but the real work begins once the update is released.

Why This Refresh Matters

GSA issues periodic MAS “refreshes” to keep contract terms aligned with evolving rules and policies. But Refresh #30 stands out. It’s designed to sync the MAS Solicitation with the sweeping changes from the Revolutionary FAR Overhaul (RFO)—the government’s biggest procurement rewrite in years.

Here’s what GSA plans to do:

  • Update dozens of clauses and provisions with new GSA-issued deviations
  • Highlight new guidance on MAS ordering procedures on GSA.gov
  • Revise the MAS solicitation instructions (SCP-FSS-001)
  • Update the Special Item Number (SIN) for Order-Level Materials (OLMs), impacting 60 subcategories

Contractors will have 90 days to accept the Mass Modification after it’s released.

What We Know So Far

While the full text isn’t out yet, GSA already published a list of 94 clauses and provisions that will change. According to the supporting document, “MAS Refresh 30 Clause and Provision Changes,” the update aims to:

  • Simplify acquisition requirements
  • Remove language not required by statute
  • Use clearer, more straightforward terms

GSA plans to replace 53 clauses, add five new deviation clauses, and delete 36 clauses—a sign of the government’s push toward streamlined, plain-language contracting.

A Continued Shift in Federal Procurement

Refresh #30 fits squarely within the goals of Executive Order 14275, Restoring Common Sense to Federal Procurement. With GSA leading the RFO effort, contractors can expect continued, rapid modernization of these large commercial contract vehicles.

These shifts aren’t happening through traditional rulemaking. Instead, GSA is using its deviation authority, which allows faster changes. More adjustments may follow. For most contractors, the real impact will depend on what they sell and how the new framework interacts with their business model. In theory, the RFO is designed to create less friction—not more.

What Contractors Should Do Now

With such a broad update on the horizon, early preparation is key. GSA is under pressure to increase commercial buying even while working with leaner staffing, which means contractors should prepare for a more streamlined, results-driven environment.

Here’s how to get ahead:

1. Set up your internal review process

If you don’t already have a workflow for reviewing MAS updates, now is the time to create one. Add a calendar reminder for the 90-day acceptance deadline.

2. Review your contract terms

Identify any parts of your existing contract that could be affected by the upcoming changes.

3. Align your compliance programs

Check whether your compliance systems need updates based on the new FAR/GSAR deviations.

4. Track inconsistencies with SAM.gov

GSA has warned that SAM.gov may lag behind Refresh #30. If the system still reflects outdated clauses, contracting officers will rely on the solicitation—not SAM. Document discrepancies so you have a record.

5. Get help if you need it

If any clauses are unclear or have operational implications, consider bringing in legal or compliance experts to interpret the revisions.

Do you want to understand how the refresh directly affects your contracts? Give us a call.

Get Ready: MAS Refresh 29 and Mass Modification Ahead

GSA has clarified (from an update on 21 August) that rotary aircraft (helicopters) will temporarily fall under MAS SIN 336413. This measure ensures agencies meet ongoing requirements and vendors can compete while GSA develops a long-term acquisition strategy. (GSA Interact August 26, 2025)

The GSA Federal Acquisition Service (FAS) will issue MAS Solicitation 47QSMD20R0001 – Refresh #29 in August 2025. Contractors must accept the associated mass modification within 90 days of issuance. (ibid)

Key Changes to the MAS Solicitation

  1. Replace Price Proposal Templates (PPTs) with new FAS Catalog Platform (FCP) Product and Services Plus Files. The PPT for “541930” Translation and interpretation services and 611630 linguistic training and education” will be replaced by the FCP Services Plus File.
  2. Update GSAR clause 552.238-103 ELECTRONIC COMMERCE with clear catalog requirements and references.
  3. Add consolidated GSAR 552.238-120 to replace legacy Economic Price Adjustment clauses 552.216-70 and I-FSS-969.
  4. Remove 19 retired Small Business Set-Aside SINs for the MAS Solicitation and all associated documents.
  5. Revise SCP-FSS-001 Instructions Applicable to All Offerors.
  6. Incorporate GSAR Change 187 updates. (ibid)

Changes to Specific Categories and SINs

  • Furniture & Furnishings (C): Revise SIN 33712 (Daycare, Preschool & Classroom Solutions).
  • IT (F): Revise SIN 518210C (Cloud Services) and SIN 54151HACS (Cybersecurity Services).
  • Miscellaneous (G): Remove Awards (G01) and Personal Hair Care Items (G04).
  • Scientific Management (I): Revise SIN 334515 (Diagnostic & Testing Equipment).
  • Security & Protection (J): Revise SIN 334220 (Surveillance Systems) and SIN 336413 (Aircraft Armoring & Helicopter Equipment). (ibid)

Questions about the MAS Refresh 29? Give us a call.

Is your SIN TDR Eligible? A deadline looms

Under the Multiple Award Schedule (MAS) Solicitation 47QSMD20R0001 Refresh 27, Transactional Data Reporting (TDR) is mandatory for all contract holders with TDR-eligible SINs. See the full list of TDR SINs on GSA’s Transactional Data Reporting requirements page. (GSA July 9, 2025)

Contractor Action Required:

  1. Accept Mass Modification A903.
  2. Submit a “Participate in TDR” modification via eMod.

Submit only a cover letter signed by an authorized negotiator with your modification. On the effective date of the TDR modification, your entire contract will be subject to TDR. Submit your modification no later than September 15, 2025. (ibid)

Questions concerning the deadline or submittal of your modification? Give us a call.

GSA eBuy Introduces New Improvements on August 14

On August 14, GSA eBuy will roll out new data elements and quality-of-life upgrades for both buyers and sellers. (Buy.GSA.Gov August 11, 2025)

For buyers:
You can now indicate whether you are requesting quotes (RFQs), proposals (RFPs), or information (RFIs). Request numbers will display updated prefixes to reflect the type of request you create (e.g., RFI1234567 or RFP8901234). (ibid)

We have also added new fields on the “request details” page so you can share more specific information about your postings:

  • Follow-on Requirement — Check Box
  • Historical Task Order Number (PIID from FPDS)
  • Previous RFI Information — Check Box
  • Commercial or Non-commercial — Radio Button
  • Contract Type — Dropdown
  • Award Method — Dropdown
  • Ordering Contracting Officer
  • Ordering Contracting Specialist (ibid)

For sellers:
You will now see this additional information, helping you match your offerings more precisely to buyer requests. (ibid)

For more details on these enhancements, see this PDF. (ibid)

Questions about how to use the new rollout? Give us a call.