Overview provided by Tiffany Baker, Managing Principal Consultant of The Gormley Group
The General Services Administration (GSA) released Multiple Award Schedule (MAS) Solicitation Refresh 33 on October 2, 2026, introducing significant updates to the MAS program. The refresh incorporates new supply chain security requirements under GSAR Part 540 and expands FASt Lane eligibility across all MAS categories. The changes apply to new task and delivery orders issued after the modification’s effective date, including orders under existing BPAs. Contractors are required to accept Mass Modification A920 within 90 days of its release. In this article, Tiffany Baker, Managing Principal Consultant at The Gormley Group, provides an overview of the changes and what MAS contractors need to know.
Changes incorporated in this modification apply to all new task and delivery orders issued after the modification’s effective date, including orders issued under existing Blanket Purchase Agreements (BPAs) (i.e., BPA calls). Orders issued before the effective date remain governed by the terms and conditions in effect at the time of award.
Changes to Overall MAS Solicitation:
Updates to the SCP-FSS-001 Instructions Applicable to All Offerors are being made. Changes include:
- Through the Revolutionary FAR Overhaul (RFO) initiative, GSA is evaluating and reimagining its acquisition system, leveraging this opportunity to integrate existing supply chain requirements formally into the GSA acquisition supplement.
- Part 540 Provision and Clause Overview
-GSA has implemented a new provision (552.540-70) and clause (552.540-71) within GSAR part 540 to strengthen the security and reliability of provided solutions, services, and products.
-Driven by a continuous dedication to supply chain security, this implementation aims to:
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- Formalize current supply chain requirements.
- Establish a consistent, transparent, and uniform agency-wide framework to minimize inconsistencies.
- Align with legislative and regulatory mandates.
- Enhance overall security and threat mitigation efforts.
To provide further details on the timing of this implementation, examples of supply chain risks, and the impact on Offerors and Contractors, please refer to the one-page flyer and FAQs. This info is also available on GSA.gov under the “Supply Chain Security” section on the “GSA Resources” tab.
- Expansion of FASt Lane eligibility to the entire solicitation.
- Revise the FASt Lane eligibility criteria to allow offerors across any MAS Large Category to be considered for FASt Lane designation only when a validated federal requirement is demonstrated through agency sponsorship or documented customer demand.
What Is Not Changing:
- Startup Springboard participation will continue to be limited to contractors approved as FASt Lane participants.
- Current FASt Lane eligibility requirements and participation standards will continue to apply to eligible FASt Lane participants.
- FASt Lane modification processes will remain limited to the IT Category and will continue to apply only to designated FASt Lane-eligible initiatives.
What Is Changing:
- Opening FASt Lane eligibility to all MAS categories.
- FASt Lane eligibility for categories other than ITC will be for offers only.
- Qualifying offerors can seek FASt Lane consideration if agency requirements are supported by verifiable, compelling customer needs.
See attached pertinent GSA files related to Refresh 33:
GSA Refresh 33 Provision Clause Tracker
Highlighted Changes to Refresh 33
SF30 Attachment for Refresh Mod
Need help reviewing and accepting MAS Refresh 33? Reach out to The Gormley Group here.