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Refreshes

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.

MAS BPAs, are a good thing

When federal agencies need to place product or service orders, on a recurring basis, they often turn to Multiple Award Schedule (MAS) blanket Purchase Agreements (BPA.).

A MAS BPA is an agreement established by an authorized ordering activity with a Schedule contractor to fill repeat demands for supplies or services, in accordance with FAR 8.405-3.  MAS BPAs and all succeeding orders have the same terms and conditions as the initial Schedule contract. MAS BPAs save the government time and money and give agencies control over their procurements. (GSA Interact August 18, 2021)

MAS BPA benefits:

  • Easier for agencies to fill recurrent needs
  • Efficient for agencies contracting for similar types of work
  • Savings in the form of volume discounts
  • Consistency within the terms and conditions of the BPA
  • Decreases in procurement costs, acquisition time, and administrative effort
  • Small business set-aside procedures assist the government in meeting socioeconomic goals (ibid)

MAS BPA features:

  • On-Ramps – allowing additional contractors as required or to refresh small business participation
  • Funding – funding is required only when an order is placed
  • Faster Ordering – more streamlined ordering process
  • Estimated Value – no minimums or caps
  • Agency Level Terms and Conditions – agencies may add terms and conditions as long as there is no conflict with the original MAS contract terms and conditions
  • Category Management – as outlined by the Office of Management and Budget, all MAS BPAs support category management (ibid)

As a mechanism for promoting fair competition, FAR 8.405.3(a)(3)(i) states a preference for multiple-award MAS BPAs. In addition, MAS BPAs may be extended past five years if necessary to meet program requirements. Some agencies have long-term MAS BPAs to meet agency missions. (ibid)

A single-award MAS BPA can not exceed one year, however, it may have four one-year options. The head of an agency approves all single-award BPAs exceeding $100M. In addition, Order Level Material (OLM) procedures are allowable at the BPA or order level to add contract support items, making MAS BPAs a win for government agencies and contractors. (ibid)

Questions about MAS BPAs or a GSA Schedule award? Give us a call.

 

Digital Certs, Out; Docusign, In

As of 30 November 30, all Multiple Award Schedule (MAS) holders are required to use DocuSign to digitally sign Documents in eOffer and eMod. (GSA Interact, October 28, 2020)

Additionally, GSA plans for the eOffer and eMod system to join FAS systems, including FAS Sales Reporting Portal (SRP), GSA Advantage Purchase Order Portal, GSA Vendor Portal, eBuy Seller, and the Mass Mod Portal, using GSA’s FAS ID multi-factor authentication (MFA). GSA’s FAS ID, allows contractors to access GSA applications using a single email and password. This transition will take place in Q2 of 2021.

During 25 – 29 November, contractors and offerors will not be allowed to submit offers and/or requests for modifications in eOffer and eMod. GSA advises planning ahead! If your document requires a contracting officer’s signature, it must be obtained by 23 November 2020. (ibid)

Digital certificates are required until the transition to DocuSign and GSA FAS ID is complete. Although digital certificates are not required once DocuSign is complete, those certificates may be required by other government agencies or private companies, therefore GSA advises holding onto your hard copies. (ibid)

Scrambling to get those documents signed by November 23rd? Give us a call.

 

 

Not a “tricky” October 31st Deadline

A Multiple Award Schedule deadline is fast approaching. All contractors must do the following to remain in compliance with the MAS Consolidation Mass Mod A812:

  1. Update your catalog in GSA Advantage
  2. Update your Price List (text file) (GSA Interact September 8, 2020)

To remain in GSA Advantage, your SIP or EDI catalog to the consolidated MAS SINs must be updated before October 31, 2020, or you risk disruption to your catalog status or access to eTools. To accomplish the update, see the SIP/EDI Catalog Update Guide. All catalog submissions must be approved by your CO. (ibid)

Additionally, all schedule holders must update their Price List (Text File) using the MAS Consolidation Price List Guide, organizing their contract offerings under the new SIN structure. (ibid)

To aid contractors with their updates, webinars are being offered as well as a Vendor Support Center Help Desk at ve************@*sa.gov or call 877-495-4849. (ibid)

Having trouble getting your questions answered? Give us a call.

FAR 51 Deviation Authority is expired!

Here’s what you need to know.  Contracting officers were permitted to give contractors access to the Federal Supply Schedule (FSS) and GSA Global Supply Programs if appropriate, for the fulfillment of their agency requirements. They used the FAR 51 Deviation Authority vehicle for this purpose. On 23 October, the FAR 51 Deviation expired. It will no longer be used on orders placed after this date. Under Refresh 1, clause CI-FSS-056 Federal Acquisition Regulation (FAR) Part 51 Deviation Authority (Federal Supply Schedules) (Jan 2010) is deleted.

In lieu of FAR 51 Deviation, agencies may use Order Level Material (OLM) procedures to acquire other direct costs (OCDs) and material support items to meet specific order requirements. Additional information for OLMs may be found at www.gsa.gov/olm.

Many question if a contracting officer can issue a letter of authority (required by the Deviation) anytime during the life of the order, if the order or BPA was awarded on or before 23 October 2019. The short answer is yes, as long as the order was issued prior to the 23 October Deviation expiration date. However, if the BPA was awarded prior to then, and subsequent award terms were awarded after 23 October, those subsequent award terms may not use the deviation.

Wondering if you are grandfathered in and still able to take advantage of the FAR 51 Deviation Authority? Give us a call.