GSA MAS Refresh 29 is Live: What Changed, What To Do, and How To Stay Compliant

GSA’s MAS Refresh 29 has been released. It brings a consolidated EPA clause, shifts offers to FCP templates, completes the retirement of SBSA SINs, and updates multiple SIN instructions. Most importantly for busy contractors, it sets clear expectations around Mass Mod acceptance timing, EPA method identification, and how TDR, offers, and modifications interact with FCP. This article distills the official announcements and the written webinar Q&A into a concise, actionable guide.

• Executive summary
• Why the new EPA clause matters now
• FCP transition and the files you must use
• Catalog compliance reminder
• FCP migration timeline
• TDR requirements and deadlines
• Mass Mod acceptance timing
• Category and SIN level highlights
• Quick action checklist for MAS contractors
• Selected Q&A highlights from GSA’s webinar
• How Price Reporter can help
• Sources

Executive summary

• Mass Mod acceptance – accept within 90 days of issuance shown in your contract’s Mass Mod notice.
• EPA is consolidated under GSAR 552.238-120 – legacy EPA clauses are replaced. Existing contracts keep their current EPA method until a trigger happens, but you should proactively file a T&C mod to identify your EPA method now.
• EPA method identification – submit one T&C mod to establish or revise the EPA method and mechanism. Later EPA price actions do not require another T&C mod unless you change the method.
• Annual escalations – fixed annual escalation for products is permitted within the new EPA framework, subject to GSAM rules.
• FCP templates for offers – new offers must use FCP Product or FCP Services Plus files. Existing contracts use the same format they were awarded under for future mods. A small set of SINs must still use SIN-specific PPTs.
• TDR scope unchanged – Refresh 29 does not expand TDR to all SINs. If your contract includes one or more TDR-eligible SINs, opt into TDR by September 15, 2025.
• MFC and BOA monitoring – if you participate in TDR, MFC and BOA monitoring requirements end on the effective date of your TDR modification.
• Category updates – notable SIN clarifications include drones under 334220 and aircraft-related guidance under 336413. SBSA SINs are fully retired from the solicitation.

Why the new EPA clause matters now

GSA added a new consolidated clause, GSAR 552.238-120 Economic Price Adjustment – FSS Contracts, which supersedes 552.216-70 and I-FSS-969. It standardizes price adjustment procedures and preserves many flexibilities previously communicated in guidance. For existing contracts, your current EPA method remains in place until a trigger such as an add-items mod, option exercise, or a request to change the EPA method.

Action to take
Do not wait for a trigger. File a T&C mod to identify or confirm your EPA method and mechanism so future price actions do not stall. GSA confirmed you only need this T&C mod once to establish the EPA method; later EPA mods do not require another T&C mod unless the method changes. Fixed annual escalations are allowed where compliant.

FCP transition and the files you must use

• Offers – new MAS offers must use FCP templates: FCP Product File for products and FCP Services Plus File for services and training. The translation and language training SINs move to the same Services Plus file.
• Modifications – use the same file format type your contract was awarded under. If you were awarded using legacy PPTs, continue with PPT for those mods. If you were awarded with FCP, continue with FCP.
• Exceptions – certain SINs must still use SIN-specific PPTs, including 531, 531110, 561599L, 561510, 561599, 4PL, 485, 532112, 492110, 492210, 532111, 481211O, and 481211B.
• Offers already under review – if your offer was already under GSA review when Refresh 29 hit, you do not need to resubmit in the new FCP format.
• Known system note – some T&C mods that need an updated Seller Profile File may not yet flow cleanly between eMod and FCP. GSA is aware. Continue working with VSC support if you encounter issues.

Catalog compliance reminder

GSA added a note to GSAR 552.238-103 Electronic Commerce emphasizing that contractors must comply with GSA catalog submission and maintenance rules. Detailed guidance is available via the FCP Help page.

FCP migration timeline

GSA’s target to complete FCP migration is anticipated by 1/1/2027. Plan development and data hygiene workstreams accordingly.

TDR requirements and deadlines

• No new SINs – Refresh 29 does not expand TDR eligibility.
• Mandatory participation window – if your contract includes one or more TDR-eligible SINs and you have not opted in yet, submit a Participate in TDR mod by September 15, 2025. TDR reporting becomes effective the first day of the next sales quarter shown in your mod.
• Compliance impact – with TDR participation, MFC and BOA monitoring end on the effective date of your TDR mod.

Mass Mod acceptance timing

Contractors must accept the Mass Mod associated with Refresh 29 within 90 days of issuance as displayed for your contract. Do not miss this acceptance window, since later modifications may depend on it.

Category and SIN level highlights

• 334220 Surveillance Systems, UAS Drones, Body Cameras, Vehicular Video – the updated description explicitly covers UAS and drones, plus related parts and ancillary services when part of a total solution. This is now the only MAS SIN covering UAS and drones.
• 336413 Aircraft Armoring and Helicopter Equipment – SIN instructions clarify that sale or lease of complete aircraft is excluded. Ordering agencies are responsible for identifying any aircraft-specific requirements at order time.
• Rotary aircraft notice – GSA clarified that rotary aircraft will be temporarily considered within scope of 336413 to ensure mission coverage while a long-term strategy is developed.
• 518210C Cloud Computing – SaaS offerings no longer need to meet the first NIST cloud characteristic regarding on-demand self-service for unilateral provisioning. Other NIST characteristics still apply. Align commercial ordering with this clarification.
• 54151HACS HACS – alignment shifts from specific NICE work role IDs to general alignment with the current NICE Framework.
• SBSA SINs – removal of SBSA SINs from the solicitation is complete, reducing administrative burden while preserving order-level set-asides.

Quick action checklist for MAS contractors

1. Accept your Mass Mod within 90 days of its issuance date.
2. Submit a T&C mod to identify your EPA method under GSAR 552.238-120, even if you do not need a price change today. This prevents delays when you do.
3. If you have TDR-eligible SINs, file the Participate in TDR mod by September 15, 2025 and prepare to report from the first day of the next applicable sales quarter.
4. Verify your file formats – use FCP for new offers. For mods, stick to the format used at award unless you are in a SIN that still requires a SIN-specific PPT.
5. Plan EPA strategy – if suitable, set up compliant fixed annual escalations and documentation under the new clause.
6. Map catalog compliance against the FCP Help guidance and resolve any eMod to FCP integration hiccups with VSC support.
7. Review SIN impacts – especially drones under 334220 and aircraft-related items under 336413 – to ensure your scope, parts, and ancillary services are positioned correctly.

Selected Q&A highlights from GSA’s webinar

• Does Refresh 29 expand TDR to all SINs – No. TDR remains limited to eligible SINs.
• Offer already under review – No need to migrate to FCP templates before award.
• TDR opt-in deadline – If your contract has TDR-eligible SINs and is not yet opted in, file by September 15, 2025.
• New EPA clause effect – existing EPA method stays until a trigger. Consolidated clause streamlines process and preserves key flexibilities.
• Annual escalation on products – permitted when compliant.
• Do I need a T&C mod with every EPA mod – No. File a T&C mod once to establish the EPA method. Later EPA mods do not need another T&C mod unless you change methods.
• What happens to MFC and BOA with TDR – they no longer apply after your TDR mod is effective.
• Which templates for mods – use the same template type you were awarded under. New offers must use FCP.

How Price Reporter can help

• EPA readiness – we will establish or confirm your EPA method via a T&C mod, verify escalation mechanics, and prepare your supporting documentation.
• TDR onboarding and reporting – we will assess eligibility, file the Participate in TDR mod, and stand up your reporting workflow.
• FCP file conversions – we will move offers to FCP templates and keep existing contracts on the correct award format for mods.
• Catalog and SIN alignment – we will validate FCP catalog compliance and align your scope for updated SIN guidance, including drones under 334220 and aircraft-related items under 336413.

If you want us to review your contract’s specific exposure and prepare the required mods, contact us and mention “Refresh 29 Review.” 

Email: salesteam@pricereporter.com

Phone: 201.567.6646

Sources

• Significant Changes Attachment for MAS Refresh 29.
• Refresh 29 Webinar Q&A.