MAS orders are getting more flexible - but compliance still controls the process.
GSA’s updated guidance on Order-Level Materials (OLMs) and contractor use of other MAS contracts gives agencies and contractors more room to build complete solutions under MAS orders. But that flexibility comes with very specific rules.
OLMs can support the order, but they cannot lead it.
OLMs must not become the primary purpose of the task or delivery order. They must be clearly identified as OLM products or services, priced at the order level, and supported by a fair and reasonable price determination.
The contractor must have the OLM SIN.
Before using OLMs, ordering activities should confirm that the MAS contractor’s contract includes the OLM SIN. GSA also notes that not every MAS contract has been modified yet to allow OLMs under the updated FSS ordering procedures.
Documentation is not optional.
Separate line items or clear sub-line items should be used for OLMs, and the quote/invoice should properly identify them. Price analysis, market research, historical pricing, IGCEs, or other support may be needed to document fair and reasonable pricing.
MAS-to-MAS purchasing can reduce open-market complexity.
GSA also confirms that MAS contractors may obtain products or services from other MAS contracts to support an order. This can help agencies meet complex requirements while staying inside the MAS environment.
No double IFF. Ever.
When one MAS contractor buys from another MAS contractor to support an order, the sale is reported and the Industrial Funding Fee is remitted only once – by the selling MAS contractor. The procuring contractor does not add a second IFF or report that portion of the sale.
For contractors, the message is clear: successful use depends on clean order structure, accurate invoicing, proper SIN coverage, and strong documentation.
