On January 19, 2025, the General Services Administration (GSA) released Refresh 24 of the Multiple Award Schedule (MAS) solicitation. This marks the first update of the year, introducing several key modifications aimed at improving procurement efficiency and reducing administrative complexities.The most significant change in Refresh 24 is the elimination of Small Business Set-Aside (SBSA) Special Item Numbers (SINs). This shift represents a major restructuring of how small businesses engage with the GSA’s MAS Schedule. While the removal of SBSA SINs may seem concerning at first, it is actually designed to simplify procurement processes for small businesses and enhance their ability to compete for government contracts.
- The End of SBSA SINs: What It Means
- Three-Step Plan for SBSA SIN Removal
- What SBSA SIN Holders Should Do Next
- Brief Overview of Other Changes in Refresh 24
- Conclusion
In addition to the SBSA SINs removal, Refresh 24 includes important clarifications in solicitation instructions, updates to Price Proposal Templates, and new subgroup classifications for certain SINs. These changes reflect GSA’s continued efforts to streamline contract management and align the MAS program with evolving federal procurement policies.
In this article, we’ll dive into why SBSA SINs are being phased out, the steps involved in their removal, and what it means for businesses currently holding these SINs. We’ll also briefly touch on other key updates included in Refresh 24.
The End of SBSA SINs: What It Means
Small Business Set-Aside (SBSA) Special Item Numbers (SINs) were originally created as a workaround to help small businesses secure government contracts under the GSA Multiple Award Schedule (MAS). Historically, federal procurement regulations did not allow set-asides under multiple-award contracts like the GSA Schedule. As a result, SBSA SINs were introduced to carve out specific categories exclusively for small businesses, ensuring they had a dedicated space to compete.
Reasons for Their Removal: Why This Change Makes Sense
The federal procurement landscape has evolved over the past decade. Regulatory changes now allow set-aside task orders and Blanket Purchase Agreements (BPAs) under the standard MAS Schedule, making SBSA SINs redundant. Instead of being a necessary tool for small businesses, SBSA SINs have become an unnecessary administrative hurdle.
By eliminating SBSA SINs, GSA aims to simplify the contract structure, reducing the need for businesses to manage multiple contracts while still ensuring that small businesses retain access to exclusive set-aside opportunities. This change is expected to improve efficiency, enhance competition, and ultimately make it easier for small businesses to secure government work.
Clarification: Small Business Set-Asides Still Exist
A crucial point to understand is that the removal of SBSA SINs does not eliminate small business opportunities under the GSA Schedule. Agencies will still be able to issue set-aside task orders and establish set-aside BPAs, specifically for small businesses.
For small businesses currently holding SBSA SINs, this change does not mean a loss of access to government contracts; it simply means that their offerings will now be categorized under the standard SIN structure, making it easier to manage contracts and compete effectively.
Three-Step Plan for SBSA SIN Removal
To ensure a smooth transition for businesses affected by the removal of Small Business Set-Aside (SBSA) SINs, GSA has implemented a three-phase process. This phased approach allows existing SBSA SIN holders to adapt, transfer their contracts, and continue competing for government opportunities under equivalent non-SBSA SINs.
Step 1: SBSA SINs Closed to New Awards (January 19, 2025)
As of January 19, 2025, all SBSA SINs have been closed to new awards under GSA Refresh 24. This means:
- No new contractors can be awarded SBSA SINs.
- Businesses already holding SBSA SINs can continue operating under their existing contracts.
Step 2: Transition to Equivalent SINs (Until May 2025)
Between now and May 2025, GSA will actively assist SBSA SIN holders in transitioning their contracts to equivalent non-SBSA SINs. The goal is to ensure businesses retain their ability to provide services and products under the GSA MAS contract without disruption.
During this transition period:
- Companies with SBSA SINs must modify their contracts to reflect an equivalent non-SBSA SIN.
- GSA will cancel SBSA SIN contract numbers once all offerings are successfully transferred and there are no active task orders or BPAs under the SBSA contract.
Businesses should review their assigned SINs and prepare for this transition as early as possible to avoid delays or compliance issues.
Step 3: Official Removal of SBSA SINs (May 2025)
By May 2025, GSA will issue another solicitation refresh, officially removing all SBSA SINs from the MAS contract structure. After this final phase:
- All transitions should be completed, with companies fully operating under their new SIN classifications.
- Any remaining SBSA SIN contracts will be invalid and no longer recognized under the MAS program.
This transition aligns with GSA’s broader efforts to simplify procurement, reduce administrative burdens, and create a more streamlined experience for both small businesses and government buyers.
Closed SBSA SINs and Their Non-SBSA Equivalents
To facilitate this transition, GSA has mapped each closed SBSA SIN to an equivalent non-SBSA SIN. Below is a comprehensive list of affected SINs:
Furniture and Furnishings
| Subcategory | SBSA SINs Now Closed to New Awards | Equivalent Non-SBSA SIN |
| Flooring | 314110SBSA – Carpet Flooring (SBSA) | 314110 – Carpet Flooring |
| Household Dormitory and Quarters Furniture | 337122SBSA – Household, Dormitory & Quarters Furniture (SBSA) | 337121H – Household, Dormitory & Quarters Furniture |
| Miscellaneous Furniture | 337122OSB – Park, Recreational & Outdoor Furniture (SBSA) | 337122O – Park, Recreational & Outdoor Furniture |
| Miscellaneous Furniture | 337127CFSB – Cafeteria and Food Service Furniture (SBSA) | 337127CF – Cafeteria and Food Service Furniture |
| Miscellaneous Furniture | 337127CISB – Correctional Institution Furniture (SBSA) | 337127CI – Correctional Institution Furniture |
| Miscellaneous Furniture | 337215MSB – Mail Sorting and Distribution Furniture (SBSA) | 337215M – Mail Sorting and Distribution Furniture |
| Healthcare Furniture | 337127CSB – Chair, Convalescent (SBSA) | 339113H – Healthcare Furniture |
| Miscellaneous Furniture | 337127LFSB – Library Furniture (SBSA) | 33721 – Office Furniture |
| Miscellaneous Furniture | 337127TLSB – Tables and Lecterns (SBSA) | 33721 – Office Furniture |
| Miscellaneous Furniture | 33721SBSA – Storage (SBSA) | 33721 – Office Furniture |
| Miscellaneous Furniture | 337215SBSA – Wall Units and Displays (SBSA) | 33721 – Office Furniture |
| Household Dormitory and Quarters Furniture | 3FURNISH – Commercial Office Furnishings (SBSA) | FURNISH – Commercial Office Furnishings |
Miscellaneous
| Subcategory | SBSA SINs Now Closed to New Awards | Equivalent Non-SBSA SIN |
| Awards | 339999ASB – Awards (SBSA) | 339999A – Awards |
Transportation and Logistics Services
| Subcategory | SBSA SINs Now Closed to New Awards | Equivalent Non-SBSA SIN |
| Package Delivery | 492210SB – Local Courier Delivery Services (SBSA) | 492210 – Local Courier Delivery Services |
Office Management
| Subcategory | SBSA SINs Now Closed to New Awards | Equivalent Non-SBSA SIN |
| Office Services | 561320SBSA – Temporary Staffing (SBSA) | 561320 – Temporary Staffing |
| Office Supplies | 333318SBSA – Office Security Equipment and IT Products (SBSA) | 33411 – Purchasing of New Electronic Equipment |
Industrial Products and Services
| Subcategory | SBSA SINs Now Closed to New Awards | Equivalent Non-SBSA SIN |
| Industrial Products | 3331SBSA – Clearing Equipment (SBSA) | 333112 – Lawn and Garden Equipment, Machinery, Implements, Tools, Products, and Accessories |
Professional Services
| Subcategory | SBSA SINs Now Closed to New Awards | Equivalent Non-SBSA SIN |
| Marketing and Public Relations | 323111SBSA – Photographic Services and Solutions (SBSA) | 541922 – Commercial Photography Services |
What This Means for Contractors
For companies affected by this transition, it is critical to take action now. Ensuring that your contract reflects the correct SIN structure will help you:
- Maintain eligibility for government contracts
- Avoid compliance issues and contract cancellations
- Continue competing effectively within the MAS program
Businesses should review their updated SINs, modify their contracts accordingly, and ensure they fully transition before the May 2025 deadline. GSA is actively supporting contractors through this process, but companies must take proactive steps to secure their position in the new structure.
This transition plan is not just about removing SBSA SINs; it is about modernizing the MAS Schedule, simplifying procurement for small businesses, and creating a more accessible federal marketplace.
What SBSA SIN Holders Should Do Next
With the phased removal of Small Business Set-Aside (SBSA) SINs underway, companies that currently hold SBSA SINs need to take proactive steps to transition smoothly and maintain their eligibility for federal contracts. The following guidelines will help businesses navigate the transition process and understand what to expect in the coming months.
Guidelines for Companies Currently Holding SBSA SINs
If your company currently holds an SBSA SIN, you must transition to an equivalent non-SBSA SIN before the final removal takes effect in May 2025. Here’s what you should do:
- Review GSA’s Equivalent SIN List
- Check the GSA-provided table of equivalent SINs (see previous section) to identify where your current SBSA SIN will be mapped.
- Ensure that your company qualifies for the corresponding non-SBSA SIN under the new structure.
- Monitor Communications from GSA
- GSA will directly contact SBSA SIN holders with transition instructions.
- Stay up to date by checking your GSA eOffer/eMod portal and subscribing to GSA updates.
- Prepare Your Transition Request
- If your company is eligible for an equivalent SIN, submit a modification request to GSA for the transfer.
- If your company is eligible for an equivalent SIN, submit a modification request to GSA for the transfer.
- Check for Active Task Orders or BPAs
- If you have active task orders or Blanket Purchase Agreements (BPAs) under an SBSA SIN, coordinate with the contracting officer to ensure a smooth transition.
- In some cases, contracts may need modifications to align with the updated SIN structure.
- Verify Compliance with New SIN Requirements
- Some equivalent SINs may have additional compliance or reporting requirements.
What to Expect During the Transition
- No Immediate Contract Cancellations: If you already hold an SBSA SIN, you can continue operating under your existing contract while transitioning to an equivalent SIN.
- GSA Assistance: The agency will provide support to help businesses navigate the transition process. If you have questions, GSA’s MAS helpdesk can assist with modifications.
- New Contracting Opportunities: The removal of SBSA SINs does not eliminate small business set-asides; companies will still be able to compete for set-aside task orders and BPAs under the updated framework.
By acting early and completing the transition before May 2025, businesses can avoid disruptions, maintain eligibility for federal opportunities, and benefit from a more streamlined contract management process under the new MAS structure.
Brief Overview of Other Changes in Refresh 24
While the removal of Small Business Set-Aside (SBSA) SINs is the most notable change in GSA Refresh 24, this update also includes several important regulatory adjustments. Specifically, Refresh 24 incorporates provisions from Federal Acquisition Circular (FAC) 2025-02 and GSAR Change 194, ensuring compliance with the latest federal procurement standards. Along with these regulatory updates, several refinements have been introduced to clarify the solicitation process, improve contract management, and enhance vendor compliance.
Clarifications for Offerors
To improve consistency and reduce ambiguity, GSA has updated several instructions for offerors submitting proposals under the MAS program.
One key clarification applies to streamlined offers, which must now be submitted using the same Unique Entity Identifier (UEI) as the existing contract. However, an exception has been made for small businesses that are part of a Joint Venture (JV). If the JV holds a GSA MAS contract, an individual small business that participated in the JV can submit its own streamlined offer under a separate UEI, provided it seeks approval only for SINs in which it has previously performed work as part of the JV.
Another important change is the requirement to formally address prior rejections. If an offer has been previously denied, the business must submit a response letter explaining how the issues have been resolved before resubmitting its proposal.
GSA has also updated rules regarding product accessories. Previously, there was some confusion about whether accessories could be sold independently or only as part of a base product. The new language clarifies that product accessories may be offered either as stand-alone items or in combination with a primary product.
Additionally, there is now stricter enforcement of minimum experience requirements in labor category descriptions. Offerors must ensure that the experience listed for each labor category is directly relevant to the proposed work.
The waiting period for resubmitting offers after contract cancellations has also been clarified. In cases where the contract was canceled due to low sales, the company must wait 12 months before reapplying for the same SINs. However, if the company chooses to pursue different SINs, no waiting period is required. Should the contract be canceled due to non-compliance, a 12-month waiting period would apply, even if the company applies for different SINs.
Updates on Regional Compliance for CONUS and OCONUS Contracts
GSA has standardized language across all Large Category attachments to clarify compliance expectations for contracts inside and outside the Continental United States (CONUS). While some requirements apply only to the U.S., Alaska, Hawaii, and Puerto Rico, companies offering products or services internationally (OCONUS) must ensure they meet local regulatory standards. When submitting proposals for OCONUS contracts, businesses should be prepared to provide documentation demonstrating compliance with the relevant country’s procurement rules.
Adjustment to Price Proposal Template
A minor update has been made to the definition of Manufacturer Name in the Price Proposal Template for both new offers and contract modifications. This change reinforces GSA’s authority to request additional details about manufacturing locations when verifying product compliance and attributes.
Modification Guide Updates on SBSA SIN Closures
The MAS Modification Guide has been revised to reflect the closure of SBSA SINs. Additionally, Refresh 24 now formally includes the full text of Clause 52.240-1 within the Regulations Incorporated by Reference document. This clause, which was introduced in the previous refresh, reinforces compliance expectations for MAS contractors regarding cybersecurity and operational integrity. The latest version now explicitly states that, as of January 19, 2025, no new contract-level awards or modifications can be made under these SINs. Additionally, GSA has now mandated that I-FSS-600 be updated whenever contract modifications affect item listings on GSA Advantage! Previously, this was a recommended practice, but under Refresh 24, it is now a strict requirement to maintain accurate product and service information within the system..
New Subgroups for SINs Covering European Operations
To improve the visibility of vendors that can provide services in Europe, GSA has introduced new geographic subgroups for certain SINs. Companies operating under SIN 561210FAC, which covers Facilities Maintenance and Management, or SIN 541990, which includes Professional, Scientific, and Technical Services (Non-IT), can now indicate their ability to operate in Europe. This update helps contracting officers quickly identify businesses that are capable of fulfilling government contracts in that region.
These refinements in GSA Refresh 24 are part of a broader effort to modernize procurement processes, improve clarity in contract requirements, and create a more efficient marketplace for both vendors and federal agencies.
Conclusion
The removal of Small Business Set-Aside (SBSA) SINs under GSA Refresh 24 marks a significant shift in the structure of the Multiple Award Schedule (MAS). While this change eliminates a long-standing contracting mechanism, it simplifies the process for small businesses, reducing administrative burdens and streamlining contract management. More importantly, the ability to issue set-aside task orders and Blanket Purchase Agreements (BPAs) remains intact, ensuring that small businesses continue to have opportunities within the GSA marketplace.
For companies currently holding SBSA SINs, adapting to these changes is essential. Businesses should take proactive steps to transition their contracts to equivalent non-SBSA SINs before the May 2025 deadline. By doing so, they can maintain their eligibility for government contracts and position themselves for future success. The key to a smooth transition lies in understanding the new structure, ensuring compliance with updated SIN requirements, and leveraging available resources to navigate the evolving procurement landscape.At Price Reporter, we have been helping businesses successfully manage their GSA contracts for nearly two decades. With extensive experience in contract acquisition, compliance, and federal market intelligence, our team ensures that clients remain competitive and compliant amid ongoing regulatory changes. When your company is affected by the removal of SBSA SINs, our experts can guide you through the transition process, helping you optimize your GSA strategy and continue growing your presence in the federal marketplace.
