A Request to Hold Continuous Contracts is a formal document submitted by a GSA Schedule contractor to obtain approval from the General Services Administration (GSA) to temporarily maintain two overlapping MAS contracts—typically during the transition from an expiring contract to a new one awarded through the Streamlined Acquisition Process. This request is a critical step for ensuring business continuity while a contractor shifts from an older, soon-to-expire contract to a newly awarded one, especially when both contracts contain similar offerings.
Holding two active contracts is not standard practice under GSA policy, which generally aims for contractors to maintain a single MAS contract. However, GSA makes exceptions in specific transitional scenarios where dual contracts are necessary to avoid disruption in catalog visibility, pricing continuity, or order processing.
Purpose of the Request
The Request to Hold Continuous Contracts serves several purposes:
- Prevents a lapse in contract availability during the transition from an expiring to a new MAS contract
- Maintains visibility on GSA Advantage! and eBuy while the new contract catalog is being loaded and approved
- Allows time for existing task orders and Blanket Purchase Agreements (BPAs) to be closed out or migrated to the new contract
- Facilitates catalog and customer migration from the old to the new contract in an orderly, GSA-approved manner
- Protects contractors’ ongoing sales pipeline from disruption or interruption
Without this approval, GSA policy may require cancellation or deactivation of the old contract immediately upon award of the new one.
When a Request Is Needed
Contractors typically submit a Request to Hold Continuous Contracts in the following scenarios:
- Streamlined MAS Acquisition: When a contractor with a successfully expiring MAS contract uses the streamlined process to obtain a new one
- End-of-life contracts with pending catalog migration: The original contract is near its expiration date, but the new contract’s pricelist has not yet been fully uploaded and approved
- High-volume contracts: Where transition complexity (e.g., large catalog size, multiple SINs, or agency dependencies) requires additional time to finalize the transition
- Continuation of existing obligations: Where open task orders, BPAs, or government relationships depend on the availability of the original contract
The request must be submitted and approved before both contracts can remain active simultaneously.
What the Request Includes
The Request to Hold Continuous Contracts is typically a written document (often in PDF or formal letter format) that includes:
- Contractor name, UEI, and CAGE Code
- Old (expiring) MAS contract number
- New MAS contract number (recently awarded)
- Requested duration of overlap, often 3–6 months
- Rationale for why continuous contracts are necessary (e.g., catalog migration, eBuy history, customer continuity)
- Description of transition plan, including steps to close the old contract and activate the new one
- Acknowledgement that both contracts cover substantially the same scope and SINs
- Contact information for the Contract Administrator or Authorized Negotiator
The request is submitted to the contractor’s assigned GSA Contracting Officer (CO) or Acquisition Specialist.
GSA’s Review and Approval Process
Once submitted, GSA reviews the request and considers:
- Whether both contracts are for the same legal entity
- Whether both contracts cover overlapping or identical SINs
- Whether the contractor is in good standing (i.e., compliant with reporting, catalog maintenance, and IFF payments)
- Whether there’s a valid reason to allow both contracts to remain active temporarily
- The contractor’s proposed transition plan and exit strategy for the older contract
If approved, GSA issues formal written authorization allowing the contractor to temporarily hold both contracts. Typically, GSA sets a time limit (e.g., 90–180 days) and may require periodic updates or milestones for deactivating the older contract.
Obligations During the Overlap Period
Once a contractor has approval to hold continuous contracts, they must:
- Avoid duplicating listings on GSA Advantage! that could confuse buyers
- Communicate clearly with government customers about which contract to use for new orders
- Stop marketing the old contract once the new contract catalog is live and functional
- Work with GSA to sunset the original contract within the approved timeframe
- Ensure sales reporting and IFF payments are properly attributed to the correct contract
Contractors are expected to treat the transition as a temporary operational bridge—not a long-term dual-contract scenario.
Best Practices for a Smooth Transition
- Begin preparing the request early, ideally 3–6 months before the original contract expires
- Ensure the new MAS contract has all awarded SINs and approved pricing before initiating the request
- Use FAS Catalog Platform (FCP) for faster catalog activation on the new contract
- Coordinate closely with the assigned CO to keep timelines clear and well-documented
- Notify internal sales, compliance, and customer service teams to avoid order confusion
- Maintain audit-ready documentation showing compliance with the dual-contract guidelines
Conclusion
A Request to Hold Continuous Contracts is a valuable transitional tool for GSA Schedule contractors undergoing a contract renewal or replacement through the streamlined acquisition process. It enables continuity in catalog visibility and order processing while the contractor migrates fully to their new contract. However, this overlap is temporary, must be formally approved by GSA, and requires clear communication and disciplined contract management. When used properly, it helps contractors avoid business disruption while maintaining full compliance with GSA policy.
