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April Showers Usher In Significant MAS Mod Refresh

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The General Services Administration (GSA) Federal Acquisition Service (FAS) announced that a mass Multiple Award Schedules (MAS) refresh would be tentatively scheduled for April 2017.  This refresh aims to update MAS solicitations and contracts to be consistent with recent policy changes.  Some of these changes include small business subcontracting improvements; updates to Non-Federal Entity access to Schedules (including under the Disaster Purchasing Program); updates to the Service Contract Act (SCA) Wage Determinations (WDs), Trade Agreement Act (TAA) compliant countries, and Contract Price Lists; and training requirements for streamlined offers.  Other individual Schedule changes will occur as well where applicable.

Planned Changes

Purchasing by Non-Federal Entities off of the Federal Supply Schedules has now been changed to reflect the final rule issued by GSA on July 6th, 2016.  This rule clarifies access privileges of State, Local, and Tribal Governments to Federal Supply contracts.  It also further expanded the State/Local Disaster Purchasing Program to now include disaster preparation and response as well as recovery. The American National Red Cross and other qualified organizations have now also been given access to FSS contracts.  Small Business Subcontracting saw the most number of changes during this refresh.  Some of the key planned changes include:

  • Allowing contracting officers the ability to require a subcontracting plan when a small business re-represents itself as an “other than small business”
  • Requiring prime contractors with subcontracting plans on task and delivery order contracts to report order level subcontracting information (effective after November 2017)
  • Requiring prime contractors to assign North American Industry Classification System (NAICS) codes to subcontracts

The Service Contract Act (SCA)/Service Contract Labor Standards (SCLS) Wage Determinations (WDs) was updated to include a new Wage Determination index; there are no clause or policy changes currently.  The list of TAA compliant countries has now been updated to include Montenegro and New Zealand.  Contract Price Lists are now required to be submitted no later than thirty (30) days after award and any references to the Central Contractor Registration (CCR) Database have been replaced with the System for Award Management (SAM).  For successful FSS contractors who are submitting a new offer under the streamlined process, the Pathways to Success training requirement has now been removed.  Click here to view the complete list of updates.

Find Out How BH Sky Can Help Keep Your Multiple Award Schedule Contract Compliant with the Latest Refresh/Mass Mod

For more information on how BH Sky Associates can help you maintain compliance and accept GSA initiated mass modifications, contact BH Sky directly by calling 866-468-7420 or email.