GSA is preparing Multiple Award Schedule (MAS) Refresh 33 for September 2026, and the advance notice includes several changes that could affect both current MAS contractors and companies preparing new Schedule offers.
Some updates are relatively narrow and apply only to specific SINs. Others are much broader, particularly the new supply chain risk language, the expansion of FASt Lane eligibility, and a new MAS-wide rule governing product substitutions.
Importantly, this is still an advance notice and draft. GSA may revise the language before Refresh 33 is formally released. Contractors should therefore use the draft to prepare, but review the final solicitation and Mass Modification before making compliance decisions.
Refresh 33 Is Expected in September
GSA anticipates publishing MAS Refresh 33 in September 2026.
Once the associated Mass Modification is issued, existing MAS contractors will have 90 days to accept it.
The updated terms will apply to new task and delivery orders issued after the modification becomes effective, including new orders placed under existing BPAs. Orders awarded before the effective date will continue to operate under the terms applicable when they were awarded.
For contractors, this makes Refresh 33 more than a solicitation update for new applicants. Existing Schedule holders will also need to review the final changes and incorporate the new requirements into their contract administration and order fulfillment procedures.
Supply Chain Risk Reviews Are Becoming More Formalized
One of the most significant proposed changes is the incorporation of new supply chain risk requirements into the MAS offer instructions.
GSA explains that the objective is to formalize existing supply chain practices and create a more consistent and transparent framework for identifying and addressing supply chain risks.
The draft SCP-FSS-001 provides considerably more detail about what this could mean for an offeror.
Under the proposed instructions, GSA may evaluate supply chain risk associated with the company itself, its products and services, and its related supply chains. Information used in that evaluation may come from government sources, commercial third-party tools, publicly available information, and information supplied by the offeror.
The review may include areas such as:
- Corporate ownership and control
- Affiliates and subsidiaries
- Connections to prohibited or restricted entities
- Product country of origin
- Manufacturer or supplier authorization
- Letters of Supply and related documentation
- Other applicable compliance representations
The draft states that GSA intends to use a risk-based approach, meaning the depth of the review should correspond to the level of supply chain risk presented by the offer. If GSA identifies a risk that cannot reasonably be mitigated, or otherwise considers the risk unacceptable, the offeror may be removed from consideration.
Why This Matters
This language makes supply chain transparency increasingly important at the offer stage.
Companies preparing MAS offers should make sure information concerning ownership, sourcing, country of origin, manufacturer authorization, and compliance representations is accurate and internally consistent.
For product resellers in particular, discrepancies between an offer, VPP information, Letters of Supply, manufacturer relationships, and country-of-origin data could become more consequential during GSA’s review.
FASt Lane Is Expanding Beyond the IT Category
Another major proposed change is the expansion of FASt Lane eligibility across all MAS Large Categories.
This does not mean every MAS offer will automatically qualify for expedited processing.
For categories outside IT, FASt Lane will apply to offers only, and eligibility will depend on demonstrating a validated federal requirement through agency sponsorship or documented customer demand.
Several existing limitations will remain.
Startup Springboard participation will continue to be limited to eligible FASt Lane participants, while FASt Lane modification processing will remain limited to the IT Category and designated eligible initiatives.
There is also an important procedural point for companies already preparing an offer: if an offeror becomes FASt Lane eligible while its application is still pending but has not yet been submitted, the draft says it must initiate a new application through eOffer to retain that eligibility.
Why This Matters
For non-IT companies with a documented federal customer need, FASt Lane could create a new route to faster MAS offer processing.
The key, however, is the customer requirement. Contractors should not interpret the expansion as a general accelerated-processing option available simply by request.
GSA Is Adding a Clear Rule for Product Substitutions
This may be one of the most operationally important changes for product contractors.
GSA proposes adding a product substitution requirement to the General Information section of every MAS Large Category solicitation attachment.
Under the proposed rule, contractors would not be permitted to substitute another product without the buyer’s prior written approval.
Any approved substitute must also:
- Already be listed on the contractor’s MAS contract
- Be priced at or below the original item
- If the substitute costs more, be specifically approved by the customer and still be an MAS-listed item
Why This Matters
Product substitutions can arise during everyday order fulfillment when the originally ordered item becomes unavailable, discontinued, backordered, or otherwise difficult to supply.
Refresh 33 would make the boundaries much clearer: contractors should not simply replace an unavailable MAS item with what they consider an equivalent product.
This makes internal coordination between purchasing, order fulfillment, customer service, and MAS compliance teams particularly important. A commercially reasonable substitution is not automatically an acceptable MAS substitution.
Roofing SIN 238160 Is Being Clarified
GSA proposes revising SIN 238160, Roofing Products and Services Solutions, to make its scope clearer.
The revised description expressly states that the SIN may support:
- Materials only
- Services and labor only
- A combined products-and-services requirement
Most notably, GSA specifically clarifies that standalone roofing services are within scope.
For companies providing roofing services, this clarification may remove uncertainty about whether roofing labor must always accompany a product purchase.
SIN 532490P Is Expanding Its Temporary Facility Scope
GSA is also proposing substantial revisions to SIN 532490P, Lease/Rental of Pre-Engineered/Prefabricated Buildings and Structures.
The revised scope would more explicitly include pre-engineered, prefabricated, portable, mobile, modular, and tension-fabric buildings and structures used for temporary facility requirements.
More significantly, GSA proposes formalizing turnkey base camp facilities and related operational support services within the SIN’s scope.
Examples include services such as:
- Laundry
- Housekeeping
- Restroom and shower servicing
- Other operational support directly related to leased or rented temporary structures
Meals, dining operations, and food services may also be included, but only when they are part of a total turnkey base camp solution. They cannot be offered as standalone products or services under this SIN.
GSA also proposes a new subgroup for Turnkey Base Camp Facilities and Operational Support Products or Services and modification of the subgroup covering leased or rented restrooms, showers, and utility rooms.
For contractors serving emergency response, disaster recovery, temporary facilities, or base camp requirements, this is a particularly important scope expansion to review.
Bottled Water Gets a Specific Exception Under 4PL
Food and beverages generally remain outside the scope of MAS.
However, Refresh 33 proposes a specific clarification for the 4PL SIN: bottled water may be included because of the unique requirements associated with 4PL solutions.
This is a narrow exception and should not be interpreted as a broader expansion of food and beverage products under MAS.
SIN 238910 Gets Clearer Rules for Ancillary Items
GSA also proposes adding instructions to SIN 238910, Installation and Site Preparation Services.
Ancillary services, incidental products, and equipment rentals may be ordered only when they directly support products or services purchased through the Federal Supply Schedule.
For incidental products specifically, the items must be separately priced, directly support the installation or site preparation services awarded under the SIN, and be ordered together with those services.
For contractors using this SIN, the distinction between an incidental item supporting an installation project and a standalone product sale will therefore remain important.
Travel and Employee Relocation Requirements Are Also Changing
Refresh 33 includes more targeted changes for contractors operating under the Travel Large Category.
For SIN 531, Employee Relocation Solution, GSA proposes revising the Statement of Work guidelines and move-management requirements to align with updated audit and payment standards for household goods relocation services.
For SIN 561510, Travel Agent Services, GSA plans revisions to both the Statement of Work and Price Proposal Template.
Among the proposed updates are:
- A new Transactional Data Reporting section
- Additional provisions addressing VIP remote or hybrid services
- Updates to Service Level Agreements
- Revised explanatory codes aligned with GO.gov
- Two additional codes supporting certain uses of non-government funds
- A new eOffer tab for Travel Management Companies
- Mandatory ancillary CLINs intended to establish a standardized baseline of available services
Travel contractors should therefore review the final SOW and pricing templates carefully rather than assuming that accepting the Mass Modification will be the only required action.
Updated SCLS Wage Determinations
GSA also plans to incorporate the latest Service Contract Labor Standards wage determinations.
Service contractors with SCLS-covered labor should verify the applicable wage determinations once the final Refresh 33 package is published and determine whether the update affects their contract administration or pricing.
What MAS Contractors Should Do Now
Because Refresh 33 is still in draft form, contractors should avoid treating every proposed provision as final. But there is enough information to begin preparing.
A practical pre-Refresh review should include:
- Product contractors: Review current substitution procedures and make sure operational teams understand that substitutions may require written customer approval.
- Resellers: Review manufacturer authorization, VPP information, Letters of Supply where applicable, country-of-origin records, and other supply chain documentation for consistency.
- Prospective MAS contractors: Determine whether documented agency demand could support FASt Lane eligibility once the expanded program becomes available.
- SIN 238160 contractors: Review whether standalone roofing services create additional opportunities under the clarified scope.
- SIN 532490P contractors: Evaluate whether turnkey temporary facilities, base camps, or integrated operational support services fit the expanded scope.
- SIN 238910 contractors: Review how incidental products and equipment rentals are structured and priced with installation services.
- Travel contractors: Prepare to review the revised SOW and pricing templates when the final solicitation is released.
- All existing MAS contractors: Track publication of the Mass Modification and plan for acceptance within the required 90-day period.
GSA Webinar Scheduled for September 1
GSA will hold a public webinar covering MAS Refresh 33 and the upcoming Mass Modification on September 1, 2026, from 1:00 PM to 2:00 PM Eastern Time. The session will be listen-only, with questions accepted through chat.
This will be particularly useful for contractors seeking clarification on the new supply chain requirements, FASt Lane expansion, product substitution rules, and SIN-specific revisions.
The Bottom Line
The proposed changes point to three broader developments contractors should watch closely: more formal supply chain risk evaluation, tighter controls around MAS product substitutions, and broader access to FASt Lane for companies with demonstrated federal demand.
At the same time, several SIN-specific revisions could create meaningful opportunities, particularly for roofing services, temporary facilities and turnkey base camps, installation services, and certain travel contractors.
The most important point right now is that these provisions are still draft changes. Contractors should prepare based on the advance notice, but the final Refresh 33 solicitation and Mass Modification will determine the actual requirements.
Which Refresh 33 change do you expect to have the biggest impact on MAS contractors: supply chain reviews, the new substitution rules, or expanded FASt Lane eligibility?
