Why MAS Refresh 30 Matters: Interpreting GSA’s RFO-Aligned Clause Overhaul
GSA’s forthcoming Multiple Award Schedule (MAS) Refresh 30 is more than a housekeeping update; it operationalizes the Revolutionary FAR Overhaul (RFO) for schedule holders and ordering activities, thereby resetting the compliance baseline that contractors must meet to compete and perform successfully. In its draft notice, GSA’s Federal Acquisition Service previews solicitation-wide language aligning MAS with the RFO and directs users to follow the new GSAM Subpart 538.71 ordering procedures—signaling that acquisition practice, not just paperwork, is changing.
The most immediate significance for contractors is the scope and direction of clause substitutions. GSA proposes to add numerous RFO-based deviations (e.g., updated System for Award Management, small-business representations, and pricing data provisions) while removing legacy versions, consolidating duplicative requirements, and favoring plain-language formulations. For contractors, this means proposal templates, compliance matrices, and training content that reference “classic” FAR prescriptions will need re-mapping to the deviation set now controlling in MAS. Treat this as a required rebuild of your clause library rather than a patch; contracting officers will rely on the solicitation’s provisions even where SAM has not yet caught up, and GSA explicitly warns of lagging system representations.
Two targeted edits carry outsized operational consequences. First, the removal of the Professional Compensation Plan requirement from SCP-FSS-001 eliminates a frequent evaluation friction point for professional services offers; while the business discipline remains wise, its absence as a solicitation requirement may shorten lead time and reduce documentation burdens for new offers and mods. Second, GSA’s revision to I-FSS-644 drops the obligation to evidence an uninterrupted source of supply across performance. That change should simplify supply-chain substantiation at award, though prudent contractors will still maintain robust supplier risk files to satisfy responsibility and performance-risk inquiries at the order level.
Security policy is also being reshaped. New deviations introduce Security Prohibitions and Exclusions (including a representation/certification, a contract clause with Alternate I, and a refreshed “basic safeguarding” requirement), while several legacy telecom and supply-chain prohibitions are slated for deletion in favor of the new regime. This is not a relaxation; it is a consolidation under the RFO banner. Compliance teams should reconcile their Section 889/telecom, FASCSA order, and Kaspersky controls with the new security deviations to ensure their internal attestations, supplier questionnaires, and purchasing blocks match the MAS clause set they will actually sign.
The draft also tightens the government’s posture on unmanned aircraft systems. By aligning MAS with Defense Innovation Unit “Blue sUAS” approval and invoking the new security exclusions, GSA effectively narrows what can be offered, ordered, operated, or funded under Federal Supply Schedule contracts, with a prohibition milestone on or after December 22, 2025. Vendors in facilities, security, inspection, and logistics who depend on UAS-enabled solutions must scrub catalogs and order-level integrations to avoid FASC-prohibited systems and components.
Order-Level Materials (OLM) policy is likewise being streamlined. GSA proposes to revise the OLM SIN description and remove the SIN-level regulations 552.238-115 and SCP-FSS-007, while noting that system subcategory limits will persist temporarily. Contractors should update internal OLM playbooks: ordering activities will be directed to the RFO’s procedures, and your quotes, bill-of-materials controls, and downstream subcontracting should mirror those procedures to avoid protest-bait or post-award disallowances.
Finally, GSA has begun the education cycle, pointing to RFO webinars and materials. Contractors that harmonize capture artifacts—standard reps/certs, cost/pricing data practices, small-business flows, and sustainability and labor standards—with the deviation list will gain speed and predictability as Refresh 30 publishes. Those that wait will encounter bid delays, clarifications, and corrective actions as outdated language collides with the RFO-based solicitation. In short, MAS Refresh 30 is the RFO’s practical implementation for schedules: treat it as a compliance migration project, not just a reading assignment.
Disclaimer: This summary is based on GSA’s draft documents and planned clause changes; final text may differ and controls. Contractors should review the final solicitation refresh and mass modification and seek counsel on applicability to their offerings and orders.