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GSA Schedule contract

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.

GSA is about to get really big

The head of GSA’s Federal Acquisition Service told employees Thursday that the agency will manage about $400 billion in procurement under an expansion set to quadruple the size of GSA. (Next GOV/FCW March 20, 2025)

A new executive order shifts some agencies’ contracting work to GSA, which already plays a key role in government procurement. President Trump reportedly signed the order Thursday, though the text remains unavailable, and the White House has not commented. (ibid)

“We will ingest all domestic and commercial goods and services into GSA. While we won’t handle all $900 billion, we will manage about $400 billion, effectively quadrupling our size,” said Josh Gruenbaum, head of GSA’s Federal Acquisition Service. (ibid)

GSA has already piloted onboarding two to three agencies to evaluate centralized procurement. The Office of Management and Budget is currently onboarding, along with the Office of Personnel Management, which recently laid off its entire procurement team. (ibid)

“We now have a mobilized operational process to absorb procurement across the government,” Gruenbaum said. GSA plans to automate procurement and integrate talent from the agencies it will serve. (ibid)

GSA operates the schedules program, allowing agencies to buy various services and goods, and oversees several major governmentwide contract vehicles. It also serves as the government’s landlord and develops procurement strategies such as category management and best-in-class contracts.(ibid)

GSA’s acting leader, Stephen Ehikian, highlighted potential cost savings by purchasing as “one buyer on behalf of the government.”(ibid)

As GSA expands procurement operations, it continues downsizing its workforce, eliminating entire offices. Last week, the agency cut the Technology Transformation Services’ talent division and market development and partnerships division while offering Voluntary Early Retirement and Voluntary Separation Incentive Payments. So far, contracting officers remain largely unaffected.(ibid)

Employees who remain will utilize a new AI bot, recently demoed. GSA announced plans to offer the tool to other federal agencies. Ehikian has prioritized AI to reduce headcount, tasking some employees with identifying how AI can take over their work. (ibid)

The AI tool includes a chat function and an API, with plans for continuous improvements based on staff feedback. Ehikian described this as part of the agency’s “build back phase” after its “slimming down phase,” emphasizing efficiency. A meeting slide deck outlined goals such as reducing IT systems per job, centralizing data, optimizing cloud spending, and investing in shared services. (ibid)

Next week, GSA will unveil a major FedRAMP program overhaul, according to Nextgov/FCW. (ibid)

GSA also continues efforts to shrink the federal real estate footprint. Ehikian reported that the agency canceled nearly 700 leases but acknowledged instances where it reinstated leases after receiving feedback from senators and stakeholders. (ibid)

Trying to make sense of all of the new changes at GSA, give us a call.

Empowering Entrepreneurs: Unveiling the Force Behind Women’s History Month 2024

In March, we honor women’s achievements, resilience, and innovation during Women’s History Month. Women-owned small businesses (WOSBs) play a crucial role, in driving economic growth and diversity. GSA proudly empowers women business leaders, exceeding WOSB goals for the past 16 years. With over 12 million WOSBs in the US, they’re a potent force, creating jobs and shaping our economy. (GSABLOG Office of Small Business Utilization March 19, 2024)

The Associate Administrator for GSA’s Office of Small and Disadvantaged Business Utilization (OSDBU), is committed to supporting women entrepreneurs. GSA ensures WOSBs have access to government contracting opportunities. The Multiple Award Schedule (MAS) program is a premier vehicle for government sales, empowering small businesses to thrive. With just a small investment in time, WOSBs can position themselves for success. (ibid)

Federal government agencies favor buying from MAS Schedule contract holders because they are procuring approved products and services. In addition, GSA has performed the groundwork and negotiated the best price. (ibid)

For WOSBs ready to secure GSA schedules contracts, here’s how to start:

  1. Register on SAM.gov. The primary database for contractors doing business with the federal government. For more in-depth information see the SAM.gov factsheet. (ibid)
  2. Connect with your local OSDBU small business specialist. These specialists are a great resource for training, education to assist you to successfully navigate the federal marketplace. (ibid)
  3. Utilize the Forecast of Contracting Opportunities Tool. this tool can assist you in locating contracting opportunities and building business plans. (The GSA Forecast Tool Factsheet explains how to use the tool and its features.) (ibid)
  4. Benefit from GSA OSDBU support and training opportunities. GSA.gov has an Events and Training page, in addition to videos and information on doing business with GSA. (ibid)

GSA is proud of its track record, having awarded over $651 million in prime contracts and $3.7 billion in subcontracts to WOSBs in FY23. In FY24, they’ve already awarded over $187 million. Women’s History Month 2024 is a tribute to the boundless potential of today’s women-owned small businesses, driving innovation and inspiring future generations. GSA continues to support them as a vital force for economic growth and progress in our nation. (ibid)

Want to know more about how your WOSB can get a GSA Schedule? Give us a call.

Is being good enough, good enough?

With fierce competition for government contracts, one must ponder if meeting the minimum standards, is enough to win some of the most coveted contracts with the Federal Government. Vendors are finding they must set themselves apart from the competition. Compliance excellence is one way to do this.

According to a GOVCON Expert, the Defense Contract Audit Agency connected with approximately 5,800 contractors in fiscal 2021. They learned that not all contractors maintained accounting compliance. Using compliance gives contractors an edge. (GOVCONWire March 2, 2023)

The Gauge Report from 2022 gives an indication of how compliance gives contractors an edge:

  1. Nearly 66% of all solicitations call for adequate accounting systems.
  2. Government contracting firms put adequate accounting systems second on their list of top auditing challenges.
  3. Labor floor checks have increased. (ibid)

The six business systems relevant to the audit process are accounting, estimating, material management and accounting systems, purchasing, government property, and earned value. Contractors that show they have adequate business systems in these areas may have an advantage over the competition. According to the Gauge Report, accounting systems are one of the most frequent requirements in new solicitations. (ibid)

How does a contractor get an “adequate” rating? When a solicitation requires documentation, bidders must provide some form of evidence, such as a letter from the Defense Contract Management Agency (DCAA) stating that the system has been approved for use on government contracts. Many contractors do not have assessed systems, which excludes them from solicitations. (ibid)

There are three possible ways a firm can turn compliance into a competitive edge:

  1. Your company has been examined by an agency and it is determined to be “adequate.” Keep a copy of the report/determination and provide the documentation as part of the bid. (If however, deficiencies are found, fix them and obtain a follow-up audit), once an adequate determination is made, use the determination when bidding.
  2. Request a system review. Since DCAA or DCMA do reviews based on contractor requests, a strong relationship with a PCO is necessary to work on your behalf to “push” a request through. To note, the examination process can take months due to the current backlog
  3. Your company pays a commercial firm, such as a CPA, to conduct an independent examination. Some government solicitations will only accept examination findings performed by government agencies.

The government appears to be making progress. In a recent OASIS+ solicitation, the solicitation language is more flexible by following the latest procurement trend, a self-scoring system. In a self-scoring system, companies earn points for systems, clearances, certifications, and past performance, and all bidders meeting the minimum points requirement are eligible to win an OASIS+ contract. (ibid)

Your company can stay proactive by:

  1. Advocate for your company. When necessary, object to the restriction limiting SF1408 examinations be performed by “government officials.”
  2. Ask for clarification of vaguely worded compliance sections. Make certain you are clear on all sections as it may be the difference between winning or losing a contract.
  3. Make sure your company and the accounting department are knowledgeable and up-to-date with new accounting standards.
  4. Invest in cybersecurity, it will carry more weight than ever before. (ibid)

Questions concerning compliance excellence or how to get an adequate rating? Give us a call.