GSA MAS Refresh #21
The General Services Administration (GSA) released the latest Refresh #21 to its Multiple Award Schedule (MAS) contract this May, accompanied by a mass modification (mass mod) to incorporate changes to the overall solicitation, as well as modifications specific to certain Large Categories and Special Item Numbers (SINs), which apply uniformly to all existing schedule holders offering products and services.
In addition to updates to the overall solicitation, these changes pertain to Joint Ventures, examination of records by GSA, administrative fees, SIN changes, and new Transactional Data Reporting (TDR) elements.
Now, let’s dive into these changes:
Revision to Instructions Applicable to All Offerors
Clause SCP-FSS-001 was revised to clarify that the 12-month waiting period and additional documentation requirements now extend to Joint Venture partners who had a prior Schedule contract canceled or allowed to expire due to low or no sales, or non-compliance.
Further clarification regarding the Examination of Records by GSA
GSA has added a note to clause 552.238-83 to further clarify the types of records that GSA can examine from the contractor. This means that the contractor agrees to grant GSA or any other duly authorized representative access and the right to examine any books, documents, papers, and records (as listed below) involving transactions related to this contract for overbillings, billing errors, or compliance with contract clauses 552.238-81 (Price Reductions) and 552.238-80 (Industrial Funding Fee and Sales Reporting).
Note: The types of books, documents, papers and records shall include but not be limited to:
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- Eligible users of the GSA Sources of Supply and Services, as defined by OGP 4800.2I and/or subsequent orders,
- Basis of Award customers, 552.238-81 Price Reductions, and 552.238-80 Industrial Funding Fee and Sales Reporting,
- Verifying the Commercial Sales Practices (CSP-1) Form for accuracy and completeness,
- GSA MAS Contractor Team Arrangements (CTAs), and
- Authorized Dealers incorporated into the MAS contract by the Contracting Officer.
Payment by Third Party
GSA has also clarified in Federal Acquisition Regulation (FAR) clause 52.232-36, Payment by Third Party, that credit card fees or convenience fees must be included in the approved MAS price and not added as a separate line item.
Transactional Data Reporting (TDR)
As the TDR program expands to include more fields and capabilities, the following data elements have been added to the FAS SRP reporting portal to align with the updated Alternate I of GSAR 552.238-80, Industrial Funding Fee and Sales Reporting:
i. Order Date
ii. Ship Date
iii. Zip Code Shipped To
iv. Federal Customer – Treasury Agency Code
GSA has incorporated the above clause and provision updates, as necessary, through certain regulation bodies, specifically the Federal Acquisition Circular (FAC) 2024-05 and GSAR Change 179.
Changes to Large Categories Subcategories or SINs
Addition of a Standard General Information Section
This section has been incorporated into the solicitation to include the following language, clearly defining the scope of the MAS Solicitation regarding firearms, live ammunition, explosives, and artillery weapons:
Firearms and Ammunition:
GSA will not award weapons such as firearms, live ammunition, explosives, and artillery weapons under this Solicitation. This also includes components that are solely used to produce functional weapons. Components that will not be awarded under this Solicitation include, but are not limited to, barrels, chambers, bolts, trigger groups, stock, magazines, rockets, grenades, grenade launchers, mines and mortars, cases, primers, powder, and projectiles.
This exclusion does not apply to non-lethal ammunition types intended to be used for training, safety, and marking purposes.
Office Management (A):
The following SIN descriptions were revised to include multifunction printers (MFP) and multifunction devices (MFD):
- SIN 333316C – Copiers and Digital Duplicating Equipment
- SIN 333316C – Copiers and Digital Duplicating Equipment
- SIN 333316CPC – Cost-per-Copy Plan for Copiers (to include Analog, Digital, Multifunctional and Engineer Copiers)
- SIN 333316F – Flat Rate Monthly Fee for Copiers (to include Analog, Digital, Multifunctional and Engineer Copiers)
- SIN 333316OS – Overseas Copiers and Supplies
- SIN 532420C – Copier Rental Solutions
- SIN 532420LC – Operating Lease Plan For Copiers
- SIN 532420LTOP – Lease to Ownership Plans (LTOP) Copies
Professional Services (H):
SIN 541990IPS – Data Breach Response and Identity Protection:
The four supplemental proposal documents have been revised as follows:
- Document 1C (SSP Template)
Update the System Security Plan template IAW with the latest version of NIST SP 800-53
- Documents 1A (Important Definitions) and 1B (Additional Proposal Instructions)
- Update hyperlinks to the NIST CPRT catalog which shows all of the latest documentation instead of the individual documents
- Remove references to specific revisions and replace with “(latest revision)”, and added formatting for emphasis
- Add language to all the documents except 1C (SSP template) to further explain how
SSP changes (outside of GSA reqs.) are handled when they are requested at the order level.
- Add formatting to the last page of SIN 541990IPS ordering guide to emphasize the order reporting requirements.
Information Technology (F)
The GSA has implemented various changes to this large category including the following:
- Addition of a new SIN 541519CSP – Credential Service Provider: To provide a managed service offering for component or full-service Credential Service Providers (CSPs) that meet the requirements of NIST SP 800-63 Digital Identity Guidelines (current version), to include public facing and enterprise.
- Clarification for software license payments: A general information section has been added to clarify that upfront payments for software licenses delivered or accessed via SaaS are not considered advanced payments.
Additionally, it was specified that all other cloud computing services (i.e., IaaS, PaaS, SaaS) and professional services must be paid in arrears in accordance with 31 U.S.C. § 3324 and 41 U.S.C. § 4505.
- SIN 518210C – Cloud Computing and Cloud Related IT Professional Services
- The Specific Instructions section of this SIN was revised to include additional information for new offerors.
- The SIN instructions pertaining to billing were updated to remove language related to: “must adhere to the ‘pay as you go’ pricing model and must be billed in arrears in accordance with 31 U.S.C. 3324.
- SIN description removed the language: ‘migration services” as an example for specific cloud related IT professional labor categories and/or fixed-price professional services solutions.
- The following were defined as out of scope for this SIN:
- Cloud computing services (i.e., IaaS, PaaS, SaaS) are sometimes offered commercially as a cloud “token,” “gift card,” “credit,” or require purchase of a prepaid offering.
- Credits for cloud computing services (i.e., IaaS, PaaS, SaaS) that are paid for in advance and spent or used at a later time are commonly termed commercially as a cloud “token,” “gift card,” or “credit”.
- Physical hardware, non-cloud software per the NIST definition, and other artifacts acquired to support the physical construction of a private or other cloud.
- SIN 518210FM – Financial Management Quality Service Management Office (FM QSMO) Core Financial Management (FM) Solutions and IT Professional Services
- The SIN instructions pertaining to billing were updated to remove language related to: “must adhere to the ‘pay as you go’ pricing model and must be billed in arrears in accordance with 31 U.S.C. 3324.
- The following were defined as out of scope for this SIN:
- Credits for cloud computing services (i.e., IaaS, PaaS, SaaS) that are paid for in advance and spent or used at a later time are commonly termed commercially as a cloud “token,” “gift card,” or “credit”.
- Changes to SINs: 54151ECOM, SIN 541519ICAM, SIN 561422, SIN 517410, and SIN 517312.
- The SIN instructions pertaining to billing were updated to remove language related to: ‘must be billed in arrears’ in accordance with 31 U.S.C. 3324.
Travel (L)
- SIN 561510 – Travel Agent Services
- GSA has updated the Statement of Work (SOW) to accommodate changes in commercial travel capabilities and services provided by Travel Management Companies (TMCs).
In the next generation of the ETS program (ETSNext) individual civilian agencies will be tasked with requesting Travel Agent Services separately.
Reminder:
The mass modification should be accepted within 90 days of its issuance. Contracting Officers must verify the absence of any pending mass modifications without acceptance before awarding contract options or modifications.
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About The Author, Brie Paramo
Brie Paramo is an accomplished contracts professional with extensive experience in GSA schedules and GSA contracts. As a dedicated BOOST MAS consultant, she channels her expertise to assist contractors in effectively acquiring and managing their MAS contracts.