A Non-MAS Item is a product or service that is not included within a contractor’s awarded GSA Multiple Award Schedule (MAS) contract. A contractor may sell the item commercially or under another government contract, but that does not make it a MAS contract item. When a federal customer needs such an item as part of a Schedule-based solution, it can be included in the acquisition only when an appropriate procurement mechanism and applicable acquisition rules allow it.
The distinction matters because MAS orders are generally intended to acquire supplies and services already covered by Schedule contracts. Adding a Non-MAS Item to a quote does not automatically place that item under the contractor’s Schedule or give it the same contractual status as an awarded MAS product or service. Depending on the circumstances, the requirement may be handled as an open-market item, an Order-Level Material (OLM), or the contractor may need to add the offering to its MAS contract before selling it as a Schedule item.
When an Item Is Outside a Contractor’s MAS Contract
MAS contract scope is determined by what GSA has actually awarded to the contractor. A company may sell thousands of commercial products while maintaining only a portion of them on its Schedule contract. The same principle applies to services. A contractor’s general commercial capabilities can be broader than the SINs, labor categories, products, and other offerings awarded under MAS.
A product or service can therefore be a Non-MAS Item when:
- it is commercially available from the contractor but has not been awarded under its MAS contract;
- it falls outside the SINs currently awarded to the contractor;
- it is a new product that has not yet been added through a MAS modification;
- it is a service or labor category outside the contractor’s awarded Schedule scope;
- it is supplied by the contractor in other markets or under another contract vehicle but not under MAS.
This status is contractor-specific. A particular product may be a MAS item for one contractor and a Non-MAS Item for another. The fact that GSA has awarded the same manufacturer’s product to another Schedule holder does not place it on every reseller’s contract.
Contractors should therefore verify their own awarded contract rather than relying solely on a manufacturer’s federal presence or another reseller’s catalog. GSA eLibrary, GSA Advantage!, the contractor’s awarded price list and current contract documentation can help establish what is actually within the contractor’s MAS scope.
A related issue arises when a contractor holds the appropriate SIN but has not added the particular offering. Holding a broad SIN does not necessarily mean that every product or service the company could theoretically provide is automatically awarded. Contractors still need to comply with applicable MAS requirements for adding offerings and maintaining contract information.
This distinction is particularly important during proposal preparation. If an RFQ requests a complete solution containing several components, the contractor should identify which components are already on its MAS contract before presenting the entire solution as a Schedule quote.
MAS Items, Non-MAS Items, OLMs, and Ancillary Offerings
“Non-MAS Item” describes the item’s relationship to a contractor’s Schedule contract. It does not, by itself, identify the procurement procedure that should be used to acquire the item. Several different mechanisms can apply depending on the requirement.
The most important distinctions are among awarded MAS items, open-market items, OLMs, and supplies or services awarded under SIN ANCILLARY.
| Item Type | Part of Contractor’s MAS Contract? | When Identified | General Treatment |
|---|---|---|---|
| Awarded MAS item | Yes | At MAS contract level | Purchased under applicable MAS ordering procedures |
| ANCILLARY SIN item | Yes | At MAS contract level | Awarded Schedule supporting supply or service |
| Order-Level Material | Yes, through OLM authority and order-level procedures | After the individual order or BPA requirement is known | Priced and acquired under OLM rules |
| Open-market item | No | During the acquisition or order process | Acquired under applicable open-market procedures |
This table highlights an important point: an OLM should not simply be described as an ordinary open-market item added to a Schedule order. OLMs operate under a specific MAS framework and are treated as Schedule items when acquired in accordance with the applicable OLM procedures.
The ANCILLARY SIN works differently. Supplies and services under SIN ANCILLARY can be identified and awarded at the MAS contract level. Once awarded, they are Schedule contract items. This makes ANCILLARY useful for predictable supporting requirements that a contractor can define before individual orders are issued.
Open-market items remain outside the Schedule contract. FAR 8.402(f) provides a mechanism for adding items not on the Federal Supply Schedule to a Schedule BPA or individual task or delivery order when applicable conditions are met. Those items must be clearly labeled as not being on the Federal Supply Schedule.
The practical question is therefore not simply, “Is this item currently on my Schedule?” Contractors also need to determine why it is outside the Schedule and which acquisition mechanism, if any, can properly accommodate it.
Using Open-Market Items with a Schedule Order
Federal agencies sometimes need a complete solution that includes a relatively small number of products or services not available under the applicable Schedule contracts. FAR 8.402(f) addresses the addition of items not on the Federal Supply Schedule to an individual Schedule order or BPA.
The rule does not make those products or services Schedule items. Instead, it permits their inclusion when the ordering activity follows the applicable acquisition regulations.
Under FAR 8.402(f), the ordering contracting officer must generally:
- Ensure that all applicable acquisition regulations pertaining to the purchase of items not on the Federal Supply Schedule have been followed.
- Determine the price for the Non-MAS Item is fair and reasonable.
- Clearly label the item as not being on the Federal Supply Schedule.
- Include all clauses applicable to items not on the Federal Supply Schedule.
These requirements preserve the distinction between the Schedule portion of the acquisition and the open-market portion. An agency cannot avoid the rules applicable to a non-Schedule purchase simply by placing the item on the same order as MAS products or services.
This distinction should also be visible in contractor quotations. Combining Schedule and open-market items into one undifferentiated list can create uncertainty about which prices, terms, and clauses apply. A quote should make the status of each relevant line item clear when the solicitation permits a mixed solution.
Contractors should also avoid representing open-market pricing as GSA-awarded Schedule pricing. GSA has not negotiated or awarded the open-market item under that contractor’s MAS contract. The ordering contracting officer must make the appropriate determination for that portion of the acquisition.
Open-market purchasing can solve a specific acquisition need, but it is not a substitute for maintaining adequate MAS contract scope. If a contractor repeatedly offers the same product or service to Schedule customers, it may be more practical to determine whether the offering can be properly added to the MAS contract.
When OLM Procedures May Apply
Order-Level Materials address a specific problem that occurs in solution-based MAS acquisitions. Some supporting supplies or services cannot be identified until the requirements of an individual order or BPA are known. GSA’s OLM framework allows qualifying items to be acquired under specified conditions rather than requiring every possible supporting component to be awarded and priced in advance.
OLMs are defined and priced at the order level. They must be acquired in direct support of an individual task or delivery order placed against a Schedule contract or BPA and are subject to specific MAS requirements.
Among the important OLM rules are:
- the contractor must have OLM SIN authority on its MAS contract;
- OLMs must be in direct support of another awarded SIN;
- they are identified and priced at the order or BPA level rather than the MAS contract level;
- OLMs are placed under time-and-materials or labor-hour contract line item numbers;
- the ordering contracting officer determines that OLM prices are fair and reasonable;
- cumulative OLM value generally cannot exceed 33.33% of the total value of the order or BPA.
Contractors should not assume that any Non-MAS Item can simply be converted into an OLM. The OLM framework has defined conditions and restrictions. The contractor’s MAS contract must include the applicable OLM SIN, and the individual acquisition must support use of the mechanism.
The timing of identification provides a useful distinction between OLM and ANCILLARY. If a supporting item can be identified, priced, and awarded in advance at the MAS contract level, the contractor may need to consider an appropriate contract-level SIN such as ANCILLARY. OLM is designed for supporting requirements that are not known until the order level.
For example, a contractor may know that it routinely supplies a particular supporting product with its solution. If the product is predictable and fits an available MAS SIN, adding it to the Schedule may be more appropriate than repeatedly attempting to handle it as an OLM. By contrast, a unique supporting item that becomes necessary only after the agency defines a particular project can present a stronger OLM use case when all applicable conditions are satisfied.
Adding a Recurring Non-MAS Offering to the Schedule
A contractor that frequently encounters demand for the same Non-MAS Item should consider whether keeping it outside the MAS contract is efficient. Repeated reliance on open-market procedures can make quotations and ordering more complicated for both the contractor and the agency.
The alternative may be to add the product or service to the MAS contract through an appropriate modification. Whether this is possible depends on the offering, the contractor’s awarded categories and SINs, and current MAS solicitation requirements.
Before pursuing a modification, the contractor should determine:
- which MAS SIN appropriately covers the offering;
- whether the product or service satisfies that SIN’s scope requirements;
- what pricing information is required;
- whether additional technical, commercial, or compliance documentation is necessary;
- whether the contractor has the required authorization to sell the product;
- whether adding the offering affects catalog or other contract information.
This process is fundamentally different from including an open-market item on a particular order. A successful MAS modification changes the contractor’s awarded Schedule scope. Future eligible customers can then purchase the newly awarded offering under MAS procedures, subject to the contract and ordering requirements.
Contractors should also keep discontinued and replacement products in mind. When a manufacturer replaces an existing model, the successor product does not necessarily become an awarded Schedule item automatically. The contractor may need to process the appropriate modification before presenting the replacement as part of its MAS contract.
The same principle applies to services. A contractor cannot automatically treat a newly developed service package or labor category as a Schedule offering merely because it resembles work already performed under another awarded service. The contractor should verify that its MAS contract actually covers what it intends to quote.
Preventing Scope and Quotation Problems
Non-MAS Items create the greatest risk when their status is not identified until late in the ordering process. A contractor may prepare a solution, negotiate technical details with the customer, and only then discover that a critical component is not part of its Schedule contract. That can force the agency and contractor to reconsider the acquisition structure.
A better approach is to perform a contract-scope review while developing the solution. Each significant product, service, labor category, and supporting item can be mapped to the contractor’s awarded MAS contract before the final quote is submitted.
This review should answer several practical questions. Is the item currently awarded? Which SIN covers it? Is the quoted configuration the same offering included on the contract? If it is not a MAS item, does the solicitation permit open-market items or OLMs? Does the contractor hold the necessary OLM authority? Should the item instead be added through a contract modification?
Clear quotation practices are equally important. Schedule items, OLMs, and open-market items should not be presented in a way that obscures their different contractual status. The ordering contracting officer needs enough information to apply the correct procedures and determine which terms govern each portion of the acquisition.
For contractors with large catalogs, this requires ongoing MAS contract management. Commercial catalogs can change much faster than Schedule contracts. Manufacturers introduce new models, services evolve, part numbers change, and older products are discontinued. Without regular synchronization, a company’s commercial sales team can easily assume that a current commercial offering is also available through MAS when it has never been added to the contract.
A Non-MAS Item is therefore not necessarily an item that the government cannot buy. It is an item that is not currently part of the contractor’s MAS contract. The government may still be able to acquire it through open-market procedures, qualifying OLM procedures, another contract vehicle, or after the contractor properly adds it to MAS. Identifying that status before quoting the item is essential because the appropriate acquisition method determines how it must be priced, labeled, evaluated, and incorporated into the federal order.
