GSA MAS Refresh 30 Is Live: What Changed, What To Do, and How to Stay Compliant

GSA’s MAS Refresh 30 is LIVE. This refresh is significant: it incorporates major Revolutionary FAR Overhaul (RFO) deviations, restructures clauses and provisions, updates solicitation-wide instructions, changes OLM rules, and revises SIN-specific templates. It also confirms the 90-day Mass Mod acceptance requirement and makes notable edits to “Drones/UAS” guidance across all Large Categories.

• Executive summary
• Why the RFO-driven clause overhaul matters
• Action to take
• Changes to SCP-FSS-001 and Offer Instructions
• I-FSS-644 Revision: Source of Supply Requirement Removed
• FCP and Catalog Compliance
• OLM SIN: What’s changing
• Category and SIN-Level updates
• Selected Q&A Highlights (Based on Refresh 30 Draft Materials)
• Sources

Executive summary

• Mass Mod acceptance – Contractors must accept the Refresh 30 Mass Mod within 90 days of issuance. Missing this window may pause mod reviews or, at worst, lead to contract termination.
• RFO-aligned clause replacements – Dozens of FAR/GSAR clauses are being replaced with new DEVIATION versions to simplify acquisition, remove duplicative representations, and align to the new plain-language framework.
• SCP-FSS-001 overhaul – GSA significantly revised this provision to align with RFO; the Professional Compensation Plan requirement is removed.
• I-FSS-644 revision – Removes the requirement to prove an “uninterrupted source of supply.”
• Pricing Terms attachment updated – Adds new columns covering EPA mechanism, rationale, limitations, and commercial practice alignment.
• Drones/UAS restrictions updated – Only DoD DIU Blue sUAS are allowable; FAR 52.240-91 prohibits procurement and operation of FASC-prohibited UAS starting Dec 22, 2025.
• OLM SIN changes – OLM SIN aligns to RFO; OLM SIN-level regulations (552.238-115 & SCP-FSS-007) are removed, though subcategory limitations remain until a future refresh.
• 492210 PPT updated – SIN 492210 template revised to remove expedited freight shipment lines and align with 492110 SOW.

Why the RFO-driven clause overhaul matters

Refresh 30 is the first MAS refresh to fully implement the Revolutionary FAR Overhaul, which massively streamlines Federal procurement by replacing large sets of legacy FAR/GSAR clauses with plain-language Deviation versions.

GSA is deleting 30+ old clauses and adding new Deviation clauses that consolidate representations, modernize cybersecurity language, and reduce duplicative requirements.

Action to take

1. Accept the Refresh 30 Mass Mod within 90 days. This is mandatory and required at the contract level. Delaying acceptance may pause your CO’s ability to review other modifications.
2. Check your Drone/UAS offerings. Only Blue sUAS are awardable under MAS. FAR 52.240-91 prohibits procuring, operating, or using FASC-prohibited UAS after Dec 22, 2025.
3. If you use OLM, review the new SIN rules. OLM regulations are changing and SIN-level instructions 552.238-115 and SCP-FSS-007 are removed.

Changes to SCP-FSS-001 and Offer Instructions

• The Professional Compensation Plan requirement has been removed.
• The requirement to use FAS ID multi-factor authentication is reinforced.
• Guidance on how joint ventures must submit and document offers has been updated.
• The instructions now clearly state that TDR participation is mandatory if an offer includes any TDR-eligible SIN.

I-FSS-644 Revision: Source of Supply Requirement Removed

GSA is removing the requirement to prove an “uninterrupted source of supply” for non-manufacturer offers. This simplifies submissions for resellers and reduces the burden of continuous supply documentation.

FCP and Catalog Compliance

Refresh 30 itself does not change FCP migration deadlines, but by incorporating RFO rules and updated clauses, it reinforces the direction GSA established in earlier Refreshes:

• Catalog submissions must comply with GSA’s catalog management policies under GSAR 552.238-103.
• Contractors should prepare for continued transition to FCP formats (Product File / Services Plus File).

OLM SIN: What’s changing

Removed

• 552.238-115 – Special Ordering Procedures for OLM
• SCP-FSS-007 – OLM Proposal Instructions

OLM SIN New description

Order-Level Materials (OLM) means products, services, and/or solutions (a combination of products and/or services) acquired in direct support of an order placed against a 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.

Category and SIN-Level updates

ALL Large Categories – Drone/UAS Rules Updated

GSA expands the guidance to align with FAR 52.240-91 security prohibitions. Only Blue sUAS are eligible. FASC-prohibited UAS cannot be delivered or operated using Federal funds after Dec 22, 2025. Source: Significant_Changes_Attachment …

Transportation and Logistics (K)

SIN 492210 – Local Courier Delivery Services The Price Proposal Template is updated to remove expedited freight shipment lines to align with SIN 492110 SOW. Source: Significant_Changes_Attachment …

Selected Q&A Highlights (Based on Refresh 30 Draft Materials)

• Does Refresh 30 change FCP migration timelines? No. FCP migration guidance remains unchanged; Refresh 30 focuses on RFO alignment.
• Are Letters of Supply still required? Yes—only for IT and Printing categories where the manufacturer is not a VPP participant (unchanged from prior refreshes). Draft_Nov2025_SCP-FSS-001 (1)
• Does OLM become unlimited across all MAS subcategories? Not yet. Subcategory restrictions remain until a future refresh.
• Does the Pricing Terms attachment change how contractors structure their EPA mods? Yes, more transparency is required regarding EPA rationale and commercial alignment.

Sources

• Advanced Notice for MAS Refresh 30 and Upcoming Mass Modification (Revised 11/18/25)
• DraftNov2025SCP-FSS-001
• SignificantChangesAttachment for MAS Refresh 30 1
• MASRefresh30 Clause and Provision Changes- Revised (Revised 11/05/25)