The General Services Administration (GSA) MAS Refresh 31 marks a strategic shift in how transactional data, pricing, and labor are governed across the Multiple Award Schedule (MAS). This update is targeted at decision-makers who must balance compliance, operational efficiency, and procurement agility. The changes touch multiple facets of MAS administration, from data reporting requirements to category-level scope, and from clause instrumentation to implementation timelines. The overarching objective is to improve pricing transparency, contract performance visibility, and alignment with federal workforce and IT priorities, all while sustaining a stable marketplace for government buyers and approved contractors. In this blog, we break down the mandatory shifts in reporting and the new compliance boundaries that every MAS holder must navigate to maintain their contract standing.
Understanding the Core Shift: Mandatory Transactional Data Reporting (TDR)
At the center of GSA MAS Refresh 31 is a major policy change: Mandatory Transactional Data Reporting (TDR) now applies to all SINs under MAS.
This change does more than add reporting fields. It replaces the older pricing logic built around CSP-1, the Basis of Award (BOA), and the Price Reductions Clause (PRC). Once TDR is adopted, those non-TDR pricing structures no longer drive compliance in the same way. Instead, the framework shifts toward transaction-level data, giving the government and contractors a clearer view of pricing, purchasing behavior, and contract performance.
What changes under TDR
Contractors must now report a broader set of transactional data elements, including:
- Order Date
- Ship Date
- Ship-to ZIP Code
- Federal Customer (Treasury Code)
- Order Type
- Order Discount, where applicable
- Worksite, for services
- Cloud Service Type, for Cloud SINs
- UCID, for catalog-based offerings
Some of these fields are entirely new, while others move from optional to mandatory. Together, they strengthen the data foundation needed for pricing validation, order tracking, compliance monitoring, and audit readiness.
Expanded documentation requirements
GSA MAS Refresh 31 also increases supporting documentation requirements at the order level.
For example:
- For fixed-price service orders over $1 million, contractors must upload the PWS, SOW, or SOO
- For Highly Configurable Products (HCP)and Configurable Services (CS), contractors must upload invoices and Bills of Materials (BOM)
This creates a closer link between what is reported, what is delivered, and how the order is supported in the contract file.
Implementation timing and compliance impact
From an implementation standpoint, contractors must accept the TDR mass modification within 90 days. Reporting then begins in the next reporting quarter after acceptance. A critical compliance consequence is that, after TDR is adopted, PRC liability no longer applies. That is a significant operational shift, especially for teams that have historically managed pricing risk through BOA and PRC monitoring.
Why these matters
For executives, contract managers, and program leaders, this is not just a reporting update. It requires changes to:
- Data capture processes
- Invoicing workflows
- Internal governance and review controls
- Documentation practices
The benefit is better visibility into pricing behavior and contract execution. With more reliable transactional data, decision-makers can improve forecasting, strengthen risk assessment, and make more informed supplier and contract management decisions.
Q&A snapshot: Is this a one-off data dump or a continuous process? It is a continuous process that hinges on disciplined data capture, system integration, and disciplined change management across contracting, invoicing, and performance reporting. The organization that builds robust data pipelines now will reap reliability benefits across audits, pricing reviews, and performance metrics.
SCP-FSS-001 Updates and Pricing Alignments
SCP-FSS-001 has been updated and streamlined to align with the Mandatory TDR requirements and the updated pricing framework. The refresh ensures that SCP-FSS-001 reflects the new data-driven approach introduced by TDR, embedding the revised pricing structure within the broader governance model. For contractors, this means updating internal cost models, aligning bid discipline with TDR data fields, and validating that pricing proposals reflect the post-TDR framework. The goal is to eliminate misalignments between contract data and actual performance, thereby reducing the risk of pricing disputes and enabling clearer acceptance criteria for task orders.
Expert commentary: The SCP-FSS-001 updates are a prerequisite for harmonizing the pricing narrative with the new data regime. When the pricing mechanism is coherently tied to transactional data, the procurement process becomes more predictable and auditable, ultimately supporting better portfolio-level decision-making and risk management.
Startup Springboard Changes and IT Focus
The Startup Springboard program is now limited to FASt Lane offers within the Information Technology (IT) category. This means faster access pathways are reserved for ITSINs that align with federal IT initiatives and require agency sponsorship. While this narrows the scope, it also crystallizes a clear path for IT-focused initiatives that aim to accelerate procurement for mission-critical IT capabilities.
Requirements for startup springboard participation are specific: applicable only to Information Technology SINs, require agency sponsorship, and must align with federal IT initiatives. For decision-makers, this creates a more predictable lane for IT-focused innovation within MAS, while ensuring governance and alignment with federal IT priorities.
Order-Level Materials (OLM): Expanding Use and Catalog Strategy
Order-Level Materials (OLM) have seen expanded usage across MAS, with fewer subcategory restrictions and a stronger emphasis on flexibility. The changes reduce open-market flexibility in favor of OLM usage, signaling a preference for standardized, price-validated components that can be rapidly integrated into configurations or services. Contractors are encouraged to add the OLM SIN where appropriate, and a one-time modification opportunity is provided to add OLM where it has not yet been awarded.
In practical terms, OLM expansion means more procurement activity can be fulfilled via MAS-based ordering, with OLM serving as a mechanism for efficiently assembling and pricing configurable products and services. This shift places additional emphasis on catalog management, item-level traceability, and accurate BOM/invoice alignment to maximize the benefits of OLM-enabled procurement.
Scope, Clauses, and Compliance: Out-of-Scope Items and Clause Changes
The refresh furnishes a clearer definition of items that are not allowed under MAS, strengthening governance over catalog composition. Explicitly excluded items include refurbished or reconditioned items (except toner), automotive parts, non-specialized toys and clothing, most food items (with certain exceptions under SIN 311423), musical instruments, and promotional items. Contractors are instructed to remove non-compliant or out-of-scope items from their catalogs, underscoring the critical role of catalog hygiene in MAS compliance.
Clause changes are a central pillar of Refresh 31. Added Clauses cover Service Contract Labor Standards, Minimum Wage (Executive Order 14026), Paid Sick Leave, Copeland Act, Subcontracting requirements (FAR 52.244-6), Environmental requirements (including ozone-depleting substances), and GSAR provisions such as Industrial Funding Fee (IFF), Price Reductions, and Modifications. Updated Clauses include the Small Business Subcontracting Plan (new alternate), Child Labor (updated for 2026), Security Prohibitions, and Apprentices and Trainees. A Deleted Clause involves FAR 52.204-27 (ByteDance/TikTok prohibition). Firearms policy has been refined to exclude replica weapons and inert ordnance, and templates have been simplified.
What this means for contractors is twofold: first, a tighter compliance baseline that requires ongoing governance across labor standards, environmental requirements, subcontracting, and workforce protections; second, a need to revise templates, forms, and governance checklists to reflect updated clause language and new prohibitions. For executives, these changes translate into clearer accountability for contractual obligations and a more consistent risk posture across MAS engagements.
Category, SIN-Level Changes Across MAS: A Practical Summary
The refresh includes substantial updates across all categories and SINs, with many changes designed to harmonize scope, workflow, and compliance expectations.
- In the Office Management category, for example, the Office Supplies SIN 339940/OS4 sees the 80/20 rule removed and the entire catalog concept eliminated, yielding a more precisely defined scope that excludes items like general IT products, furniture, cleaning supplies, and restroom products. Remanufactured toner remains an allowed item, illustrating a nuanced boundary between new and remanufactured offerings. Contractors are urged to remove all out-of-scope items from catalogs and to ensure documentation aligns with updated scope requirements.
- The Printing and Photographic Equipment SIN 333249 now includes 3D printing (additive manufacturing) within its scope, expanding the portfolio to cover equipment, materials, software, services, and lifecycle support. Facilities SIN 311423, Non-Perishable Food Products, is now closed to new offers and is scheduled for retirement in a future refresh, signaling a planning horizon for catalog rationalization.
- In the Information Technology category, SAP-like labor category differentiation by SIN becomes more explicit, while SIN 561422, Automated Contact Center Solutions (ACCS), expands to encompass AI, chatbots, robotic process automation (RPA), and interactive voice response (IVR). The approach requires labor to be integrated into total solution offerings rather than offered as standalone labor, emphasizing end-to-end capability delivery.
- The Miscellaneous category highlights OLM’s broader applicability, reinforces its cross-subcategory utility, and encourages adoption across MAS. In Professional Services, SIN 541211, Auditing Services, shifts the validation focus from individual CPA requirements to task-order-level evaluation, reflecting a performance-based oversight approach. Training SINs updates remove outdated references and consolidate alignment with DAU and FAI anchors, while Transportation and Travel-related SINs undergo template simplifications and updated references, including KPI development for travel-related performance.
Security considerations receive added emphasis, with ongoing requirements for SOC 2 Type II and PCI DSS compliance, as well as updates to FedRooms and related pricing and terminology.
The overarching takeaway for implementation teams is to map these category-level shifts onto internal catalog governance, bid preparation, and risk management processes. The changes are designed to drive consistency, reduce scope ambiguity, and improve the reliability of MAS-based procurement decisions.
Also Read: Upcoming GSA MAS Refresh 31
What Your Team Must Do:
Immediate actions are clearly defined: accept the TDR mass modification within 90 days, update systems to capture the required TDR data, and train teams on the new reporting requirements. Catalog hygiene becomes a strategic priority, with a particular emphasis on removing out-of-scope items and ensuring that the Office Supplies SIN catalog reflects the revised scope. Contractors should add the OLM SIN if it is not already awarded and prepare for a one-time modification opportunity to include OLM where needed.
From a contracting perspective, add or align with the updated SCP-FSS-001 instructions, and ensure that all proposals reflect the new TDR-driven data structure. Do not submit non-TDR offers; the proposal process must be synchronized with the new transactional data approach. For decision-makers, the GSA MAS Refresh 31 creates an imperative to re-evaluate the catalog strategy, data governance, and negotiation levers. Align internal policies, enterprise data models, and procurement workflows with the TDR framework to reduce risk and enable more informed decision-making across MAS engagements.
For organizations seeking tailored, risk-managed guidance through these changes, iQuasar’s GSA MAS services can help orchestrate your MAS readiness program. We ensure a pragmatic, phased approach to adoption, governance, and performance measurement that minimizes disruption while maximizing compliance and value realization.
