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GSA MAS Refresh 30: What the Revolutionary FAR Overhaul Means for Contractors
The landscape for government contractors operating under the GSA Multiple Award Schedule (MAS) program is slated for significant updates. GSA anticipates that Refresh 30 will occur in November 2025, bringing with it pivotal changes designed to align the solicitation with recent governmental regulatory transformations. These planned revisions stem directly from the Revolutionary FAR Overhaul (RFO).
Preparing for Comprehensive Regulatory Alignment
The upcoming refresh and subsequent mass modification will introduce several crucial changes across the entire MAS Solicitation. GSA will be modifying various clauses and provisions to fully integrate deviations to the Federal Acquisition Regulation (FAR) and the General Services Administration Acquisition Regulation (GSAR) established by the RFO.
Contractors should note that the provision SCP-FSS-001 is also scheduled for updates to maintain consistency with the new FAR and GSAR deviations resulting from the RFO. Additionally, the solicitation will be updated to include a clear directive pointing users to GSA.gov for detailed guidance on MAS ordering procedures. Specifically, ordering activities must adhere to procedures outlined in RFO GSAM Subpart 538.71—Federal Supply Schedule Ordering Procedures for placing orders and establishing Blanket Purchase Agreements (BPAs) against Federal Supply Schedule (FSS) contracts.
The OLM SIN Undergoes Revision
Perhaps one of the most operationally significant changes within the refresh affects the Order-Level Materials (OLM) Special Item Number (SIN), which falls under the Complementary SINs Subcategory. GSA is revising the OLM SIN description to align it fully with the updates implemented under the RFO.
What are Order-Level Materials (OLMs)?
OLMs are defined as products, services, and/or solutions—or a combination thereof—that are acquired to directly support an individual order placed against an FSS contract, including orders under FSS BPAs. Critically, these materials must be items or services that were not known at the time the FSS contract or BPA was awarded. It is essential to remember that OLM pricing is not established in the FSS contracts or BPAs themselves.
New Rules for OLM Usage
The use of the OLM SIN is strictly limited to 60 OLM-eligible subcategories within the MAS program. When utilizing the OLM authority, supplies and services must be acquired in direct support of an individual task or delivery order placed under one of these eligible subcategories.
Furthermore, if the OLM SIN is used in conjunction with a SIN that is eligible for Cooperative Purchasing, then the OLM SIN itself also becomes Cooperative Purchasing Eligible.
Contracting Officers working on the ordering activity side must adhere to the specific procedures outlined in RFO 538.7104-2, which governs the process for adding OLM to an order. More detailed information related to the OLM SIN is available on the gsa.gov website.
60 Eligible OLM Subcategories
The authority to use OLM applies to a defined list of 60 subcategories, including essential areas such as:
- IT Services and Solutions: IT Hardware, IT Services, IT Software, and IT Training.
- Facilities Management: Facilities Maintenance and Repair, Facilities Services, and Facilities Solutions.
- Professional Services: Business Administrative Services, Financial Services, Human Resources, Marketing and Public Relations, and Legal Services.
- Security and Safety: Protective Equipment, Security Services, Security Systems, and Fire/Rescue/Safety/Environmental Protection Equipment.
- Equipment and Supplies: Office Furniture, Industrial Products, and Medical Equipment.
- Training and Education: Training, and Language Services.
The upcoming Refresh 30 underscores GSA’s commitment to standardizing procurement processes under the guidance of the Revolutionary FAR Overhaul. Contractors should closely review the final solicitation refresh when it is released to ensure full compliance with the updated clauses and procedures, especially those concerning Order-Level Materials.
Tags: GSA MAS, Refresh 30, RFO, FAR Overhaul, OLM SIN, Government Contracting, Federal Acquisition, GSA Schedules, marketus