Upcoming GSA MAS Refresh 34: What Every Contractor Must Know Before November 2026

GSA has published the advanced notice for MAS Solicitation Refresh 34, with the refresh anticipated in November 2026. The comment period is open for ten business days from the date of posting. All comments must be submitted in the Comments section of the GSA Interact post. GSA will consider all relevant feedback before finalizing the refresh, but will not issue formal responses to industry comments. Contractors should review the final solicitation refresh and mass modification for full details when published.

Refresh 34 is one of the most structurally significant refreshes in recent memory. It incorporates the final wave of the GSAR Overhaul, introduces a new AI-related clause for all GSA contracts including Schedules, adds a voluntary FSS domestic end product certification, initiates a nitrile glove removal process tied to a DHS Best-in-Class contract, and delivers targeted SIN-level changes across Facilities and Information Technology. In this blog, we break down every confirmed change from the official Refresh 34 significant changes document so MAS contractors can assess compliance obligations and prepare before November.

Key Changes to the Overall MAS Solicitation

1. GSAR Overhaul Wave 4:

The most operationally significant change in Refresh 34 is the incorporation of GSAR Overhaul Wave 4 final updates across GSAR Parts 538 and 539. This represents the culmination of a multi-year regulatory modernization effort that GSA calls “evergreen contracting.” The goal is to reduce administrative burden, improve regulatory agility, and consolidate decades of piecemeal FSS clause development into a cleaner, more coherent structure.

GSAR Part 538: Federal Supply Schedule Program

Wave 4 removes the 20-year limitation on contract duration under clause 552.238-116. This is a structural change to how long FSS contracts can remain active. Additionally, GSA is deleting 41 existing GSAR provisions and clauses, removing eight FAS FSS homegrown clauses, and replacing them with five new consolidated GSAR clauses numbered 552.238-190 through 552.238-194.

The 16 GSAR clauses that remain in place after Wave 4 are:

• 552.238-77, Pricing and Catalog Data
• 552.238-79, Cancellation
• 552.238-80, Transactional Data and Contract Fee Requirements
• 552.238-82, Contractor Initiated Modifications
• 552.238-83, Examination of Records by GSA (Federal Supply Schedules)
• 552.238-112, Definitions — Federal Supply Schedule Contracts
• 552.238-113, Authorities Supporting Use of Federal Supply Schedule Contracts
• 552.238-115, Order-Level Materials Requirements
• 552.238-116, Option to Extend the Term of the FSS Contract
• 552.238-117, Failure to Provide Accurate Information — Price Adjustment
• 552.238-190, Federal Supply Schedule Contractor Team Arrangements
• 552.238-191, Federal Supply Schedule Contract Requirements
• 552.238-192, Federal Supply Schedule Order-level Requirements
• 552.238-193, Product Offering and Sales Requirements
• 552.238-194, Sales Criteria
• 552.516-90, Economic Price Adjustment

Important note from GSA: Wave 4 does not revise FSS ordering procedures located in GSAR 538.71. Those revisions were incorporated through MAS Refresh 30 and are currently being processed via rulemaking. Additional details and resources are available at Acquisition.gov on the RFO page.

GSAR Part 539: New AI Clause (552.239-7001)

Refresh 34 introduces GSAR Part 539, which creates a new AI-related clause for use in GSA contracts, including all MAS Schedule contracts. The new clause is 552.239-7001. The stated purpose is to protect Government Data and mitigate risks presented by Large Language Model (LLM) systems. This clause is not limited to IT contractors. It applies across the full MAS solicitation, meaning every contractor regardless of large category needs to understand what 552.239-7001 requires regarding AI use, data handling, and LLM-related risk.

2. FSS Domestic End Product Certification (GSA CD-2026-04)

Refresh 34 introduces a new voluntary clause under GSA Class Deviation CD-2026-04: GSAR clause 552.238-130, Federal Supply Schedule (FSS) Domestic End Product Certificate.

• What the Clause Does

Offerors and contractors on FSS contracts are permitted but not required to certify that listed products are FSS domestic end products. An FSS domestic end product means a product that meets all three of the following conditions:

• The product is offered for sale on the offeror’s or contractor’s GSA Schedule contract
• The product is manufactured in the United States
• If the product does not consist wholly or predominantly of iron or steel, the cost of components mined, produced, or manufactured in the United States exceeds 75% of all component costs. If the product does consist wholly or predominantly of iron or steel, the cost of foreign iron or steel mill products used in manufacture is less than 5% of total component costs
• Certification Format

Contractors who choose to certify complete a product-level table listing the Product Name, Manufacturer Part Number, and Manufacturer Name for each certified item. The certification constitutes a material representation of fact to the Government. An erroneous or false certification exposes the contractor to remedies under the False Claims Act (31 U.S.C. 3729 et seq.) and the Administrative False Claims Act (31 U.S.C. 3801-3812).

Resellers and dealers may rely on OEM-provided information when making certifications, provided they use commercially reasonable best efforts to identify and utilize generally available data.

• OMB Clearance Pending

GSA is currently seeking OMB clearance for information collections related to clause 552.238-130. Until clearance is received, GSA will not enforce compliance with clause requirements and will not share information received under this certification. Contractors may offer the certification voluntarily in the interim, but enforcement does not begin until OMB clearance is granted.

3. Covered Nitrile Gloves: Planned MAS Removal

Consistent with an OMB memorandum dated August 31, 2026, GSA intends to remove from MAS contracts items that fall within the scope of DHS’s Best-in-Class PPE Safety Stock contract for domestically manufactured nitrile gloves. This action supports consolidation of federal demand and a stronger domestic PPE supply chain.

The current offerings in scope include:

• Powder-free, medical-grade nitrile gloves in 4 mil and 5 mil blue varieties
• 6 mil black variety

GSA intends to engage directly with affected contractors to validate which items fall within scope and to consider contractor feedback before proceeding with removal. Contractors currently offering these specific nitrile glove variants on their MAS contracts should prepare for direct GSA outreach and begin assessing the impact of potential removal on their catalog and revenue mix.

SIN-Specific Changes

Facilities Large Category (B)

SIN 561210FAC — Facilities Support Services

GSA is removing the HVAC Maintenance subgroup from SIN 561210FAC and revising SIN notes to eliminate HVAC maintenance as a standalone offering under this SIN.

The new SIN instruction makes the scope restriction explicit. GSA will not award MAS contracts to offerors offering only standalone service types such as janitorial, plumbing, electrical, or HVAC maintenance. These services must be performed by contractors providing Complete Facilities Maintenance.

The only standalone services that remain allowable under SIN 561210FAC are for offerors performing HVAC services that can demonstrate experience in all of the following:

• Boilers, Chillers, and Refrigeration systems
• Maintenance of Fire Alarm Systems and Maintenance of Fire Suppression Systems
• Elevator/Escalator Inspection Service and Elevator/Escalator Maintenance Service

Contractors currently holding SIN 561210FAC under the HVAC Maintenance subgroup should assess whether their scope of services meets the revised standalone HVAC requirements. Those who do not meet the new criteria will need to evaluate whether to modify their schedule offerings or remove the SIN.

Information Technology Large Category (F)

SIN 54151HACS — Highly Adaptive Cybersecurity Services

GSA is phasing out the voluntary Incident Response subgroup under SIN 54151HACS at the end of Fiscal Year 2027. This subgroup will be retired, not simply renamed.

Contractors currently holding the Incident Response subgroup who do not hold the Incident Handling and Event Management (IHEM) subgroup should evaluate their eligibility for IHEM placement now. The IHEM subgroup incorporates Incident Response capabilities. Transitioning to IHEM before the FY2027 retirement deadline ensures continuity of schedule coverage for these service types.

Contractors who already hold the IHEM subgroup are not affected by this change.

Also Read: GSA MAS Refresh 33: Key Changes Every Contractor Must Know

Key Takeaways

• GSA anticipates MAS Refresh 34 in November 2026. The comment period closes ten business days after the October 6, 2026 posting date.
• GSAR Wave 4 removes the 20-year contract duration limit, deletes 41 existing GSAR provisions and clauses, removes eight FAS homegrown clauses, and consolidates them into five new GSAR clauses (552.238-190 through 552.238-194).
• New AI clause 552.239-7001 under GSAR Part 539 applies to all MAS contracts regardless of category. Contractors using AI in performance or reporting workflows must assess compliance requirements when the final text publishes.
• New voluntary clause 552.238-130 allows FSS domestic end product certification. The certification is a material representation of fact carrying False Claims Act liability. OMB clearance is pending and enforcement has not yet begun.
• GSA plans to remove certain nitrile glove variants from MAS contracts per an August 31, 2026 OMB memorandum. Affected contractors should expect direct GSA outreach.
• SIN 561210FAC eliminates the HVAC Maintenance subgroup and restricts standalone HVAC services to providers demonstrating experience across boilers, chillers, fire systems, and elevator/escalator maintenance.
• SIN 54151HACS is phasing out the Incident Response subgroup at end of FY2027. Contractors should evaluate IHEM subgroup eligibility now.

What Contractors Should Do Before November 2026

All MAS contractors:

• Submit comments on the advanced notice through the GSA Interact post within ten business days of October 6, 2026
• Review the 16 remaining GSAR clauses against your current contract terms
• Assess how the new AI clause 552.239-7001 affects your AI tool usage in performance and reporting
• Monitor Acquisition.gov for final GSAR Wave 4 and RFO resources

Product contractors:

• Evaluate whether any listed products qualify for the voluntary 552.238-130 FSS domestic end product certification
• Confirm whether any nitrile glove offerings fall within the DHS BIC PPE Safety Stock scope and prepare for GSA outreach

Facilities contractors:

• Audit current SIN 561210FAC offerings against the revised standalone HVAC requirements
• Determine whether your scope meets the new Boilers, Chillers, Fire Systems, and Elevator/Escalator maintenance criteria
• Initiate a modification if offerings no longer align with the revised SIN scope

Cybersecurity contractors:

• Review current HACS subgroup holdings against the IHEM subgroup requirements
• Initiate placement in the IHEM subgroup before FY2027 if not already holding it
• Do not wait until the Incident Response subgroup retires to begin the transition

For MAS contractors who need support assessing Refresh 34 compliance implications, managing mass modification acceptance, navigating the new AI clause requirements, or responding to SIN-level scope changes, iQuasar’s GSA MAS services team provides hands-on contract management and compliance support. Contact us today to stay compliant and ahead of every refresh deadline.

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