GSA Issues MAS Refresh # 31 – What Contractors Need to Know
The General Services Administration (GSA) Federal Acquisition Service (FAS) has issued Refresh # 31 to the GSA Multiple Award Schedule (MAS) Solicitation 47QSMD20R0001. Refresh # 31 introduces several significant changes that require action from MAS contractors. Changes apply to all new task and delivery orders issued after the effective date, including orders under existing BPAs.
TDR Is Now Mandatory for All MAS SINs
The most significant change in Refresh # 31 is the full expansion of Transactional Data Reporting (TDR) across the MAS program. TDR is now mandatory for every SIN under the Schedule.
GSA will issue a Mass Modification A909 Participate in Transactional Data Reporting (TDR) to all contractors not yet participating in TDR. Contractors must accept this modification within 90 days of issuance. TDR participation begins on the first day of the next sales reporting quarter following acceptance, and Price Reductions Clause liability ends on that same date.
Non-TDR offers that have not been withdrawn will be rejected by GSA. Contractors with pending non-TDR offers should withdraw and resubmit under TDR requirements.
Refresh 31 also adds several new mandatory TDR data elements, including Order Type (all offering types), Cloud Service Type (Cloud SIN only), Unique Catalog Identifier where applicable, Order Discount (limited circumstances), and Worksite (services under T&M and Labor Hour contracts). Four previously optional elements — Ship Date, Order Date, Zip Code Shipped To, and Federal Customer Treasury Agency Code — also become mandatory.
Office Supplies SINs 339940 and 339940OS4 — Scope Narrowed
GSA is removing the 80/20 rule and eliminating all references to furniture, restroom products, and IT items as authorized offerings under the Office Supplies subcategory. Contractors currently holding these SINs with IT products, furniture, or other out-of-scope items on their contracts will be required to remove those items via a modification request. Affected contractors will also need to complete an updated Letter of Compliance.
OLM SIN — Subcategory Restriction Removed; Open Market Items Impacted
GSA is revising the Order-Level Materials (OLM) SIN to eliminate its subcategory limitation, allowing it to function like any other MAS SIN. Critically, the broad discretion that previously allowed open market items within MAS orders has been replaced with a structured, OLM-based approach under GSAR 538.71 and 538.72. Items previously accepted as general open market additions must now meet specific OLM requirements.
GSA strongly recommends all MAS contractors add the OLM SIN. A one-time Mass Modification A815, Implementation of Order Level Material (OLM) SIN will be offered to current contractors who do not yet have it.
Non-Perishable Foods SIN 311423 — Closing
SIN 311423 will be closed to new offers and modifications as of Refresh 31 and is scheduled for full retirement with Refresh 32.
TikTok/ByteDance Clause Replaced by Broader Security Clause
The standalone ByteDance/TikTok prohibition clause (FAR 52.204-27) has been deleted and replaced by the expanded Security Prohibitions and Exclusions clause (FAR 52.240-91, Alternate I). The new clause covers TikTok/ByteDance restrictions, Kaspersky Lab-covered articles, prohibited telecommunications equipment (Huawei, ZTE, Hytera, Hikvision, Dahua), drone prohibitions under the American Security Drone Act, and FASCSA order compliance. Contractors must flow these requirements down to subcontractors.
Startup Springboard Program Restricted
The Startup Springboard Program is now limited to offerors that also qualify under FASt Lane, which is restricted to the Information Technology Category. Newer firms outside of ITC will no longer be eligible to use the Startup Springboard pathway.
NOTE: GSA did NOT include the proposed AI clause (GSAR 552.239-7001) in Refresh 31. The AI clauses may be included in the next Refresh 32.
Action Items for MAS Contractors
For existing GSA Multiple Award Schedule (MAS) Contractors, GSA will issue a bilateral modification to apply the changes for Refresh # 31. Contractors will have 60 days to accept the issued mass mod. Failure to accept this modification prior to the due date may result in loss of access to GSA eTools and/or cancellation of the subject contract.
If you have any questions on the significant changes or accepting the Mass Mod A914 for Refresh # 31, Participate in TDR or OLM’s, please contact BH Sky for assistance.
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