GSA proposes sweeping changes to Multiple Award Schedule program

The General Services Administration has released a draft of several changes it plans for the Multiple Award Schedule program, a government-wide initiative for agencies to acquire commercial products and services.

Known as Refresh 31, the changes include making transactional data reporting mandatory as well as new terms and conditions for artificial intelligence and restrictions on open-market items.

GSA wants comments on the draft changes to be submitted by March 20.

The changes to transaction data reporting, or TDR, will apply to all MAS special item numbers by adding 112 SINs that were previously exempt. GSA will require contractors to report detailed sales transaction data to GSA on a quarterly basis.

Once finalized, current MAS contract holders will receive a mass modification for the TDR requirement and must accept the change within 90 days.

Other parts of Refresh 31 will also trigger mass modifications with a 60-day acceptance requirement.

Part of the TDR change includes an end to the Price Reductions Clause, which requires contractors to notify GSA if they offered a better price for a product or service to a customer.

This means that contractors will no longer have to track commercial price changes. GSA is also looking to reduce exposure to retroactive price reductions or payment demands, which have been the basis for False Claims Act lawsuits.

The new AI provisions will standardize terms and conditions government-wide for the first time. GSA is incorporating provisions from the Office of Management and Budget’s M-25-22 memo from April 2025, Driving Efficient Acquisition of Artificial Intelligence in Government.

OMB's memo requires agencies to include contract terms that require vendors to get permission before using non-public government data to train their publicly-available AI algorithms. In other words, the government continues to own and control its data.

A second provision in the memo says agencies will monitor AI systems for performance with ongoing testing and monitoring rights built into contracts.

For the new open market items, GSA is restricting their use. In its place, GSA will institute a structured approach through the Order-Level Materials SIN.

Previously, contracting officers had broad discretion to add items outside a contractor's schedule to MAS orders. GSA is replacing that flexibility with a more structured process.

“Given these changes, it is strongly recommended that you add the OLM SIN,” GSA writes in the draft.

Comments are due March 20 and should be emailed directly to maspmo@gsa.gov.