For just over a year, the federal government has been running a strange experiment in technology procurement. Through its OneGov program, the General Services Administration (GSA) put leading enterprise artificial intelligence (AI) platforms in agencies’ hands for $1 or less. Three of those offers were set to expire on September 30, 2026.

Now we know what comes next, at least for one of them. On September 10, GSA announced the first agreement in the next phase of its OneGov AI strategy. The $1 price was replaced by a 27-month consumption-based arrangement running from October 1, 2026, through December 31, 2028. During this period, agencies pay no platform fee and make no minimum commitment, but they pay for usage at 50% off token-based pricing. Usage eligibility extends not only to all three federal branches but also to state, local, and tribal governments. GSA notes that the deal includes a one-year check-in and requires providers to report utilization and cost-savings data (feeling very transactional data reporting-esque).

So the free trial isn’t exactly over, but the flat price that never rose with use is gone. That changes the question for agencies. It’s no longer about whether to try it; it’s about what the technology costs at scale and what it would cost to exit.

At a Glance

  • GSA’s first next-phase OneGov AI agreement replaces the $1 flat price with consumption-based pricing at 50% off token-based rates and no platform fee or minimum commitment.
  • The introductory deals gave agencies time to begin integrating AI tools into their workflows, making migration costs and vendor lock-in important considerations as pricing changes.
  • New GSAR clause 552.239-7001 requires data portability, limits restrictions that could impair migration, and gives the government significant rights over government data and certain related custom developments.
  • Contractors should identify which orders carry the new clause, reconcile it with their commercial terms, and prepare for applicable usage reporting, data export, and downstream compliance obligations.

Moving In: A Year Is Long Enough to Get Comfortable

In announcing the deal, the acting commissioner of GSA’s Federal Acquisition Service said that “agencies wanted the ability to try new technologies before committing to a lengthy acquisition” and “providing consumption-based access is the next logical step.” GSA, with marked candor, says its AI agreements have expanded access to AI tools for roughly 3.5 million federal employees.

There’s no denying that running a $1 deal for approximately a year created demand and dependency in the federal government that will linger. A year is long enough for employees to learn an interface, for developers to wire systems into it, and for agencies to build workflows and governance around a particular tool that later becomes indispensable. Essentially, it was enough time for entities to move in together and adopt a pet. Now, the real price of the next order includes migrating data, rebuilding workflows, retraining staff, additional security validation, and whatever else the switch could disrupt.

The Question GAO Never Popped

Last year, a small business protested two of the $1 arrangements, arguing that the “$1 unlimited annual license pricing structure” was inconsistent with commercial practices and risked “an impermissible vendor lock-in scenario.” The Government Accountability Office (GAO) dismissed both protests on December 18, 2025 (B-423826 and B-423827), without reaching the merits. GSA had implemented the offers by modifying a reseller’s Federal Supply Schedule contract, and GAO generally does not review post-award modifications, which are matters of contract administration. The out-of-scope exception did not help, because the protester was a supplier or subcontractor to the schedule contractor, not an actual or prospective offeror, and so was not an interested party.

Now that agencies are paying by the token, they are about to find out whether they are locked in with particular vendors.

The Vows from M-25-22 Kept the Lock-In Concern

Back in 2024 we wrote about Office of Management and Budget Memorandum M-24-18, which pushed agencies to minimize vendor lock-in when buying AI. Its April 2025 replacement, M-25-22, keeps that focus. It says agencies “must pay careful attention to vendor sourcing, data portability, and long-term interoperability to avoid significant and costly dependencies on a single vendor.” It tells agencies to signal interest in proposals that reduce lock-in through knowledge transfer, data and model portability, clear licensing, and pricing transparency and, where applicable, to include contract terms that reduce the risk that switching vendors becomes cost-prohibitive. Where practicable, agencies should also reevaluate an AI system’s value periodically and set criteria for sunsetting it. Whether any of that made it into the $1 deals isn’t public, but GSA has now put a ring on it by putting it in a clause.

Trouble in Paradise? GSA Drafts a Postnup

GSA has now moved beyond its previous guidance with a one-sided postnup. Through its General Services Administration Acquisition Regulation (GSAR) overhaul class deviation, RGO-2026-01, it has added GSAR 552.239-7001, Basic Safeguarding of Data within Large Language Model Artificial Intelligence Systems. The clause applies when the government buys a large language model (LLM), chatbot, agentic system, or similar tool in which LLM functionality is a material feature and government data goes into or comes out of the model. GSA has made its revised GSAR clause effective October 19, 2026, and GSA’s advance notice for Multiple Award Schedule (MAS) Refresh 34, planned for November 6, says the refresh will add it.

Not surprisingly (or maybe totally surprisingly), much of the clause is about data security, including a bar on training models with government data and 72-hour incident reporting. Several provisions, though, read like a postnup. The contractor must support the export of government data in open or standard machine-readable formats, with the metadata and schema needed to migrate it, and may not impose proprietary formats, technical restrictions, added costs, or licensing conditions that materially impair migration. It must give 30 days’ notice before replacing or materially changing a model unless it provides concurrent access to the successor. And the clause takes precedence over conflicting commercial terms.

To the extent that government data is used for any improvements or enhancements, it isn’t a half-and-half split of the assets—all rights are immediately assigned and transferred back to the government. While it’s understandable that the government doesn’t want to show favoritism or give one company an advantage over another, this disincentivizes companies from providing the government with the best possible tools.

Unless the contracting officer directs otherwise in writing, when the contract or order ends, the contractor must delete government data and custom developments, including fine-tuned model weights and embeddings. Contractors should expect that request before closeout and be ready to export government data, including metadata and schema, the day an agency asks. That means building the 30-day notice into your release process, because the clause doesn’t care whether the model change was yours or an upstream provider’s. When the contract ends, delete what the clause requires and document that deletion!

Whether the clause reaches the new OneGov agreement isn’t altogether clear. GSA’s summary says the agreement incorporates GSA’s AI terms and conditions but doesn’t say whether they track the new clause. And the Refresh 34 mass mod applies only to orders issued after its effective date (and contractors are given up to 90 days to accept it). Without a doubt, contractors need to understand which of their orders carry the clause and which do not, because that determines whether an agency’s exit rights are contractual or simply whatever is stated in the commercial terms.

Buying In or Just Buying Dinner? FAR 3.501 Still Applies

Federal Acquisition Regulation (FAR) 3.501-1 defines buying in as offering below anticipated costs while expecting to recover the loss through increases after award or artificially high follow-on prices. FAR 3.501-2(a) tells contracting officers to keep those losses from being recovered through change orders or follow-on contracts subject to cost analysis.

Notably, nominal introductory pricing is not buying in by itself; that would require a below-cost offer and an expectation of recovery. GSA’s announcement doesn’t show either. A 50 percent usage discount doesn’t, on its face, look like inflated follow-on pricing, but the regulation’s concern still applies. An attractive entry price shouldn’t be judged separately from costs that arrive later, and in AI those later-arriving costs tend to show up as the cost of leaving versus the incumbent’s prices.

The In-Laws Are Still Deciding: What Comes Next for OneGov

As of this writing, the September agreement is the only one GSA has announced in this next phase. GSA extended the other two offers set to expire September 30—one through October 31 and the other through November 15, 2026—and other providers’ offers run into 2027. GSA says it is “renewing agreements where appropriate,” and whether the next deals look like the first will show whether OneGov preserves real choice once these tools are baked into the ordinary infrastructure.

Before Signing Anything

  • For schedule holders, read and heed GSAR 552.239-7001 against your commercial terms before Refresh 34 lands. List every place they conflict, and fix what you can on your side; once you accept the mass mod, you won’t get to argue about it later.
  • Incumbents should pull their usage data by agency and bureau before the one-year checkpoint, because the agency will arrive with its own numbers and they want to be the ones who already know what the bill looks like and why.
  • Challengers should stop pricing against the incumbent’s rate and start pricing the agency’s migration, then put the migration in the proposal, including who does it, how long it takes, what it costs, and what the agency keeps when it is done.

Finally, for those resellers and integrators, remember that the flow-down reaches anyone who designs, deploys, or operates the model, and the prime carries the due-diligence obligation for them. Map which of your vendors are in scope now, and renegotiate the ones whose terms will not survive the clause before a contracting officer asks you to attest to something you haven’t checked.