Federal Contracting

FAR Council Locks In the “Two-Point” SAM Rule

Federal contractors finally have the clarity they’ve needed. After years of inconsistent interpretations and protest risk, the FAR Council has confirmed exactly when an offeror must be active in the System for Award Management (SAM) to qualify for award. (Federal News Network November 6, 2025)

The answer is now simple: You must be active in SAM at two specific moments — when you submit your offer and when the government makes the award. A temporary lapse in between will no longer knock you out of the competition. (ibid)

How We Got Here: A Long Trail of FAR Confusion

The trouble began with a 2018 amendment to FAR 52.204-7. Many interpreted the new language as requiring continuous SAM registration from proposal submission all the way through award, a period that often lasts months or even years. (ibid)

Bid-protest forums like the Government Accountability Office (GAO) and the Court of Federal Claims reinforced that strict reading. Under their approach, even a brief lapse in SAM, caused by something as minor as a banking change or an unintentional delay, could make an otherwise qualified offeror ineligible. (ibid)

Contractors felt the pressure. The rule didn’t improve the government’s ability to select the best solution; it simply turned SAM upkeep into a high-stakes technical trap, especially for small businesses with frequent changes in ownership, banking, or certifications. (ibid)

Recognizing this problem, the FAR Council issued an interim rule in November 2024 clarifying that offerors only needed to be active at submission and at award, not every moment in between. (ibid)

The Final Rule: A Clear, Two-Point Requirement

On August 7, 2025, the FAR Council finalized that approach with no changes. The final rule confirms:

Offerors must be active in SAM at two moments only:
(1) when they submit the offer, and (2) at the time of award.
No continuous pre-award monitoring is required.
Mid-evaluation lapses are no longer automatically disqualifying as long as registration is active at the two required points.
Offerors must still keep SAM reps and certs accurate at all times. (ibid)

This shift materially reduces protest risk and prevents the loss of competitive proposals over minor administrative oversights. It also restores fairness to the process, ensuring that meaningful competition, not website maintenance, drives award decisions. (ibid)

What This Means for Contractors

The rule divides SAM responsibilities into two clear phases:

Pre-Award: Follow the Two-Point Rule

Be active at submission.
Be active at award.
Document both moments.

A simple screenshot or PDF of the SAM “Active” status at each point can quickly resolve any protest issues.(ibid)

Post-Award: Maintain Continuous Registration

Nothing changes here. Contractors must keep SAM active throughout performance and through final payment. A lapse during performance can still cause payment delays and contract complications. (ibid)

Also unchanged: your obligation to keep all reps and certs accurate.
An “active” but inaccurate SAM record creates a different kind of compliance risk. (ibid)

Strengthen Your Internal Processes

The two-point rule lets contractors shift focus from constant monitoring to smart coordination. This is a perfect time to align your teams:

Business Development should share projected submission and award timelines.
Compliance should flag any upcoming changes that may affect validation.
Both teams should ensure timely documentation of SAM’s active status at the two required moments.

When these processes sync, you stay compliant without wasting time chasing SAM status mid-evaluation. (ibid)

The Bottom Line

The new FAR rule delivers long-needed clarity. Instead of punishing contractors for brief, inconsequential lapses, the government now evaluates SAM eligibility at two meaningful points: submission and award. (ibid)

With basic internal controls, contractors of all sizes can easily meet these requirements, reduce protest risk, and keep their attention where it belongs — on winning and performing federal contracts. (ibid)

Do you have questions about lapses or whether you were active at submission and/or award? 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.

GSA Expands OneGov Beyond Cloud and Software

GSA is preparing to expand its OneGov initiative beyond software and cloud, creating new opportunities for technology vendors. MeriTalk September 16, 2025

“Plans for OneGov are constantly evolving, and we’re working to accommodate broader industry interests,” said Kyra Stewart, acting director of GSA’s IT Vendor Management Office, at the Sept. 16 Federal Networks event. (ibid)

Launched in April, OneGov modernizes federal IT acquisitions with standardized terms and pricing, helping agencies access the right technology while saving taxpayer dollars. Since its debut, GSA has struck deals with Oracle, Elastic, Google, Adobe, Salesforce, DocuSign, OpenAI, Box, Anthropic, and Microsoft. (ibid)

To protect agencies from sudden cost hikes when discounts end, GSA is negotiating longer-term agreements and revisiting terms before contracts expire. Stewart wants agencies to avoid vendor lock-in and manage costs effectively. (ibid)

Lawrence Hale, acting assistant commissioner at GSA’s Federal Acquisition Service, added that OneGov provides agencies with dedicated staff to find the best deals and solutions to meet their missions. (ibid)

GSA emphasized that OneGov will remain voluntary, giving agencies flexibility to choose outside providers. (ibid)

GSA’s OneGov initiative continues to evolve, creating new opportunities and challenges for contractors. Should you require support in navigating OneGov, whether it’s understanding requirements, identifying opportunities, or streamlining your participation, 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

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.
Update GSAR clause 552.238-103 ELECTRONIC COMMERCE with clear catalog requirements and references.
Add consolidated GSAR 552.238-120 to replace legacy Economic Price Adjustment clauses 552.216-70 and I-FSS-969.
Remove 19 retired Small Business Set-Aside SINs for the MAS Solicitation and all associated documents.
Revise SCP-FSS-001 Instructions Applicable to All Offerors.
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.

GSA Taps Industry to Transform Federal Contracting with AI

The General Services Administration (GSA) issued a Request for Information (RFI) today, seeking input from suppliers and industry associations to create a single, integrated, and highly efficient procurement ecosystem. This new system will incorporate Artificial Intelligence (AI) to drive collaboration and strengthen the federal acquisition lifecycle. (General Services Administration Press Release August 18, 2025)

“President Trump, through his executive orders and AI Action Plan, is prioritizing the consolidation of federal procurement and acceleration of AI adoption across government. GSA plays a central role in both these efforts and will deliver a more effective, data-driven, and unified acquisition lifecycle,” said Federal Acquisition Service Commissioner Josh Gruenbaum. “Leveraging AI to consolidate procurement processes and provide insightful recommendations is critical to this transformation. We welcome our industry partners’ expertise as we build an acquisition system that reduces waste, delivers better value for taxpayers, and better results for government.” (ibid)

The RFI represents GSA’s initial outreach to industry partners to gather their perspective on its vision for modernizing procurement. On behalf of the federal government, GSA seeks innovative solutions that apply AI and automation to existing data, structured and unstructured, to achieve greater efficiency and scalability in acquisition practices. (ibid)

GSA invites input from suppliers and associations with expertise in information technology, data architecture and storage, AI and Machine Learning, data analytics, user experience design, and innovative small businesses and startups. (ibid)

Interested parties should review the draft RFI package, which outlines the scope, objectives, functional and non-functional requirements, information about current systems, and related challenges. Respondents may submit White Papers up to 10 pages. (ibid)

Responses are due August 29, 2025. GSA will use the feedback to inform follow-on engagements, including additional RFIs, draft solicitations, and potential individual discussions. GSA anticipates issuing solicitations in support of this initiative shortly after reviewing feedback. (ibid)

Should you have questions concerning the creation of the White Paper or need guidance, give us a call.