The Federal Acquisition Service (FAS) of the General Services Administration (GSA) revealed on October 17, 2025, that it will issue a Multiple Award Schedule (MAS) Solicitation 47QSMD20R0001 “refresh” sometime in November 2025. While GSA allowed the contracting community 10 business days to submit comments—until October 31, 2025—as MAS contract holders know, GSA issues refreshes from time to time so that changes are made uniformly in recognition of shifts in policy, regulations, or statutes. Administering MAS contracts in this way allows GSA to curate terms in a consistent manner for contractual vehicles at all stages of performance, as contractors perform orders at different times.

Refresh #30
The incoming November changes, “Refresh #30,” promise to be significant because they will make several modifications to the overall MAS Solicitation. In GSA’s Summary of Changes, Refresh #30 will update numerous clauses and provisions to align the MAS Solicitation with deviations from the Federal Acquisition Regulation (FAR) and General Services Administration Acquisition Regulation (GSAR) resulting from the Revolutionary FAR Overhaul (RFO). GSA will also add a statement to the MAS Solicitation directing users to GSA.gov for more information on MAS ordering procedures, and update the instructions for the MAS Solicitation itself, the SCP-FSS-001. Finally, Refresh #30 will revise the Special Item Number (SIN) for Order-Level Materials (OLMs) to align that provision with updates from the RFO affecting 60 subcategories of materials under the MAS program.[1] Upon issuance, contractors will have 90 days to accept the Mass Modification applying Refresh #30.

As of the date of this post, the text of Refresh #30 is not yet available. GSA’s announcement, however, outlines the 94 clauses and provisions to be affected, broadly spreading the RFO changes beyond agency-specific deviations. Attached to GSA’s announcement is a document titled “MAS Refresh 30 Clause and Provision Changes,” which explains that Refresh #30 “incorporates GSA deviations that align with the revised regulatory framework” of the RFO. Specifically, GSA seeks to “simplify acquisition requirements, remove non-statutory provisions, and promote the use of plain-language clauses and provisions.” As the lists below indicate, GSA is replacing 53 existing clauses with deviations, adding five new clauses from deviations, and deleting 36 clauses.

Continued Reshaping of Federal Procurement
In light of Executive Order 14275, Restoring Common Sense to Federal Procurement (April 15, 2025), and GSA’s prominent role in spearheading the RFO, this robust pace of change is a familiar feature as the Government moves in the short term to alter these far-reaching, commercially oriented contract vehicles. Notably, these changes have been wrought not through formal regulatory rulemaking but under GSA’s deviation authority. There may be further adjustments to the provisions and clauses through that process. For contractors, however, the impact of the changes will be determined by the nature of contractor’s business, and if the intent of the RFO is to be effectuated, there should be little to no impact.

Contractors Should Prepare Now for Refresh #30
Given the breadth of changes envisioned by Refresh #30 and its imminent release, contractors should take proactive steps now to prepare for modifications to their MAS contracts. In doing so, contractors should appreciate that GSA has been directed to lead an increase in commercial-based contracting across the government, but with leaner staffing. That effort, coupled with the RFO’s impetus to strip away from the FAR any language that is not statutorily required, will mean an emphasis on clearer solutions for ordering agencies. We expect that, essentially, GSA will want to see what is working for the Government and for contractors to cull their respective offerings of those items or services that may not be selling. With this context in mind, we provide the following practical guidance:

  • If one is not already established, set up an internal review protocol to go over Refresh #30 and calendar the 90-day acceptance time frame.
  • Review contract terms and identify operational impacts, if any.
  • Determine whether any compliance programs need to be aligned with the FAR/GSAR deviations imposed by Refresh #30.
  • Document compliance with Refresh #30 and any inconsistency with SAM.gov representations. The “MAS Refresh 30 Clause and Provision Changes” document reminds contractors that the System for Award Management (SAM.gov) “may lag” behind implementation of Refresh #30. As a practical matter, contractors may be forced to complete representations in SAM.gov “based on provisions that are not included in” the MAS Solicitation. “Contracting officers will rely on representations from offers based on provisions in the solicitation. Entities are not required to, nor are they able to, update their entity registration to remove these representations in SAM.”
  • If necessary, get outside counsel assistance in interpreting revised clauses and determining how to conform operations to new legal requirements.

LISTS OF AFFECTED CLAUSES

Clauses to Be Added by Deviations, Replacing the Original Versions

  1. 52.204-7, System for Award Management (NOV 2024) (DEVIATION AUG 2025)
  2. 52.209-2, Prohibition on Contracting With Inverted Domestic Corporations-Representation (NOV 2015) (DEVIATION AUG 2025)
  3. 52.209-5, Certification Regarding Responsibility Matters (AUG 2020) (DEVIATION AUG 2025)
  4. 52.209-7, Information Regarding Responsibility Matters (OCT 2018) (DEVIATION AUG 2025)
  5. 52.212-1, Instructions to Offerors—Commercial Products and Commercial Services (SEP 2023) (DEVIATION AUG 2025)
  6. 52.215-20, Requirements for Certified Cost or Pricing Data and Data Other Than Certified Cost or Pricing Data (NOV 2021) (ALTERNATE IV – OCT 2010) (DEVIATION SEP 2025)
  7. 52.215-6, Place of Performance (OCT 1997) (DEVIATION SEP 2025)
  8. 52.219-1 Small Business Program Representations (FEB 2024) (DEVIATION SEP 2025)
  9. 52.223-1, Biobased Product Certification (MAY 2024) (DEVIATION SEP 2025)
  10. 52.233-2, Service of Protest (SEP 2006) (DEVIATION AUG 2025)
  11. 52.216-1, Type of Contract (APR 1984) (DEVIATION SEP 2025)
  12. 52.222-48, Exemption From Application of the Service Contract Labor Standards to Contracts for Maintenance, Calibration, or Repair of Certain Equipment – Certification (MAY 2014) (DEVIATION OCT 2025)
  13. 52.222-52, Exemption From Application of the Service Contract Labor Standards to Contracts for Certain Services- Certification (MAY 2014) (DEVIATION OCT 2025)
  14. 52.204-10, Reporting Executive Compensation and First-Tier Subcontract Awards (JUN 2020) (DEVIATION AUG 2025)
  15. 52.204-15, Service Contract Reporting Requirements for Indefinite-Delivery Contracts (OCT 2016) (DEVIATION AUG 2025)
  16. 52.209-10, Prohibition on Contracting With Inverted Domestic Corporations (NOV 2015) (DEVIATION AUG 2025)
  17. 52.209-6, Protecting the Government’s Interest When Subcontracting With Contractors Debarred, Suspended, Proposed for Debarment, or Voluntarily Excluded (JAN 2025) (DEVIATION AUG 2025)
  18. 52.209-9, Updates of Publicly Available Information Regarding Responsibility Matters (OCT 2018) (DEVIATION AUG 2025)
  19. 52.215-21, Requirements for Certified Cost or Pricing Data and Data Other Than Certified Cost or Pricing Data- Modifications (NOV 2021) (ALTERNATE IV – OCT 2010) (DEVIATION SEP 2025)
  20. 52.219-14, Limitations on Subcontracting (OCT 2022) (DEVIATION SEP 2025)
  21. 52.219-16, Liquidated Damages- Subcontracting Plan (SEP 2021) (DEVIATION SEP 2025)
  22. 52.219-27, Notice of Set-Aside for, or Sole-Source Award To, Service-Disabled Veteran-Owned Small Business (SDVOSB) Concerns Eligible Under the SDVOSB Program (FEB 2024) (DEVIATION SEP 2025)
  23. 52.219-28, Postaward Small Business Program Representation (JAN 2025) (DEVIATION SEP 2025)
  24. 52.219-29, Notice of Set-Aside for, or Sole-Source Award to, Economically Disadvantaged Women-Owned Small Business Concerns (OCT 2022) (DEVIATION SEP 2025)
  25. 52.219-3, Notice of HUBZone Set-Aside or Sole-Source Award (OCT 2022) (DEVIATION SEP 2025)
  26. 52.219-30, Notice of Set-Aside for, or Sole-Source Award to, Women-Owned Small Business Concerns Eligible Under the Women-Owned Small Business Program (OCT 2022) (DEVIATION SEP 2025)
  27. 52.219-33, Nonmanufacturer Rule (SEP 2021) (DEVIATION SEP 2025)
  28. 52.219-6, Notice of Total Small Business Set-Aside (NOV 2020) (DEVIATION SEP 2025)
  29. 52.219-8, Utilization of Small Business Concerns (JAN 2025) (DEVIATION SEP 2025)
  30. 52.219-9, Small Business Subcontracting Plan (JAN 2025) (ALTERNATE II – NOV 2016) (DEVIATION SEP 2025)
  31. 52.223-11, Ozone-Depleting Substances (MAY 2024) (DEVIATION SEP 2025)
  32. 52.223-12, Maintenance, Service, Repair, or Disposal of Refrigeration Equipment and Air Conditioners (MAY 2024) (DEVIATION SEP 2025)
  33. 52.223-2, Reporting of Biobased Products Under Service and Construction Contracts (MAY 2024) (DEVIATION SEP 2025)
  34. 52.223-23, Sustainable Products and Services (MAY 2024) (DEVIATION SEP 2025)
  35. 52.223-3, Hazardous Material Identification and Material Safety Data (FEB 2021) (ALTERNATE I – JUL 1995) (DEVIATION SEP 2025)
  36. 52.223-7, Notice of Radioactive Materials (JAN 1997) (DEVIATION SEP 2025)
  37. 52.233-1, Disputes (MAY 2014) (DEVIATION AUG 2025)
  38. 52.233-3, Protest After Award (AUG 1996) (DEVIATION AUG 2025)
  39. 52.233-4, Applicable Law for Breach of Contract Claim (OCT 2004) (DEVIATION AUG 2025)
  40. 52.237-9, Waiver of Limitation on Severance Payments to Foreign Nationals (DEC 2022) (DEVIATION SEP 2025)
  41. 52.223-12, Maintenance, Service, Repair, or Disposal of Refrigeration Equipment and Air Conditioners (MAY 2024) (DEVIATION SEP 2025)
  42. 52.204-13, System for Award Management Maintenance (OCT 2018) (DEVIATION AUG 2025)
  43. 52.216-22, Indefinite Quantity (OCT 1995) (DEVIATION SEP 2025)
  44. 52.222-19, Child Labor-Cooperation With Authorities and Remedies (JAN 2025) (DEVIATION OCT 2025)
  45. 52.222-35, Equal Opportunity for Veterans (JUN 2020) (DEVIATION OCT 2025)
  46. 52.222-36, Equal Opportunity for Workers With Disabilities (JUL 2014) (DEVIATION OCT 2025)
  47. 52.222-37, Employment Reports on Veterans (JUN 2020) (DEVIATION OCT 2025)
  48. 52.222-50, Combating Trafficking in Persons (OCT 2025) (DEVIATION OCT 2025)
  49. 52.222-53, Exemption From Application of the Service Contract Labor Standards to Contracts for Certain Services- Requirements (MAY 2014) (DEVIATION OCT 2025)
  50. 52.222-54, Employment Eligibility Verification (JAN 2025) (DEVIATION OCT 2025)
  51. 52.232-36, Payment by Third Party (MAY 2014) (DEVIATION OCT 2025)
  52. 52.222-11, Subcontracts (Labor Standards) (MAY 2014) (DEVIATION OCT 2025)
  53. 52.222-6, Construction Wage Rate Requirements (AUG 2018) (DEVIATION OCT 2025)

Clauses to Be Added by Deviations

  1. 52.240-90, Security Prohibitions and Exclusions Representations and Certifications (AUG 2025) (DEVIATION)
  2. 52.209-11, Representations by Corporations Regarding Delinquent Tax Liability or a Felony Conviction Under Any Federal Law (FEB 2016) (DEVIATION AUG 2025)
  3. 52.240-91, Security Prohibitions and Exclusions (AUG 2025) (ALTERNATE I – AUG 2025) (DEVIATION)
  4. 52.240-93, Basic Safeguarding of Covered Contractor Information Systems (AUG 2025) (DEVIATION)
  5. 52.208-10, Government Supply Sources (AUG 2025) (DEVIATION)

Clauses to Be Deleted

  1. 52.204-17, Ownership or Control of Offeror (JUL 2016)
  2. 52.204-20, Predecessor of Offeror (JUL 2016)
  3. 52.204-24, Representation Regarding Certain Telecommunications and Video Surveillance Services or Equipment (NOV 2021)
  4. 52.204-29, Federal Acquisition Supply Chain Security Act Orders—Representation and Disclosures (DEC 2023)
  5. 52.212-3, Offeror Representations and Certifications – Commercial Products and Commercial Services (MAY 2024) (DEVIATION FEB 2025)
  6. 52.225-25, Prohibition on Contracting With Entities Engaging in Certain Activities or Transactions Relating to Iran Representations and Certifications (AUG 2018)
  7. 52.222-46, Evaluation of Compensation for Professional Employees (FEB 1993)
  8. 52.204-18, Commercial and Government Entity Code Maintenance (JUL 2016)
  9. 52.204-2, Security Requirements (MAR 2021)
  10. 52.204-21, Basic Safeguarding of Covered Contractor Information Systems (NOV 2021)
  11. 52.204-23, Prohibition on Contracting for Hardware, Software, and Services Developed or Provided By Kaspersky Lab and Other Covered Entities (DEC 2023)
  12. 52.204-25, Prohibition on Contracting for Certain Telecommunications and Video Surveillance Services or Equipment (NOV 2021)
  13. 52.204-30, Federal Acquisition Supply Chain Security Act Orders—Prohibition (DEC 2023) (ALT I DEC 2023)
  14. 52.212-5, Contract Terms and Conditions Required to Implement Statutes or Executive Orders – Commercial Products and Commercial Services (JAN 2025) (DEVIATION FEB 2025)
  15. 52.223-10, Waste Reduction Program (MAY 2024) (DEVIATION FEB 2025)
  16. 52.223-20, Aerosols (MAY 2024)
  17. 52.223-21, Foams (MAY 2024)
  18. 52.225-1, Buy American Supplies (OCT 2022)
  19. 52.225-11, Buy American – Construction Materials Under Trade Agreements (NOV 2023)
  20. 52.225-3, Buy American – Free Trade Agreements – Israeli Trade Act (NOV 2023)
  21. 52.225-3, Buy American – Free Trade Agreements – Israeli Trade Act (OCT 2022) (ALTERNATE I – JAN 2021)
  22. 52.225-3, Buy American – Free Trade Agreements – Israeli Trade Act (OCT 2022) (ALTERNATE II – JAN 2021)
  23. 52.225-3, Buy American – Free Trade Agreements – Israeli Trade Act (NOV 2023) (ALTERNATE III – FEB 2024)
  24. 52.225-3, Buy American – Free Trade Agreements – Israeli Trade Act (OCT 2022) (ALTERNATE IV – OCT 2022)
  25. 52.225-13, Restrictions on Certain Foreign Purchases (FEB 2021)
  26. 52.225-23, Required Use of American Iron, Steel, and Manufactured Goods—Buy American Statute—Construction Materials Under Trade Agreements (NOV 2023)
  27. 52.240-1, Prohibition on Unmanned Aircraft Systems Manufactured or Assembled by American Security Drone Act – Covered Foreign Entities (NOV 2024)
  28. 52.247-65, F.O.B. Origin, Prepaid Freight–Small Package Shipments (JAN 1991)
  29. 52.208-4, Vehicle Lease Payments (APR 1984)
  30. 52.208-5, Condition of Leased Vehicles (APR 1984)
  31. 52.208-6, Marking of Leased Vehicles (APR 1984)
  32. 52.208-7, Tagging of Leased Vehicles (MAY 1986)
  33. 52.204-10, Reporting Executive Compensation and First-Tier Subcontract Awards (JUN 2020)
  34. 52.204-15, Service Contract Reporting Requirements for Indefinite-Delivery Contracts (OCT 2016)
  35. 52.222-55, Minimum Wages Under Executive Order 14026 (JAN 2022)
  36. 552.238-115, Special Ordering Procedures for the Acquisition of Order-Level Materials (SEP 2024)

[1] The provision regarding the SIN for OLMs is oriented toward ordering agencies. GSA defines OLM to mean “products, services, and/or solutions (a combination of products and/or services) acquired in direct support of an order placed against a[n] FSS contract, including orders under FSS BPAs, when the products, services, and/or solutions are not known at the time of FSS contract or FSS BPA award. OLM pricing is not established in FSS contracts or FSS BPAs.” GSAR 538.7101.