MAS Refresh 31 marks a major shift in how the MAS program operates. With new reporting and compliance requirements, contractors must adapt to a more data-driven approach. At the same time, reduced reliance on the Basis of Award (BOA) and the Price Reductions Clause (PRC) helps ease the burden of ongoing pricing compliance.
1. Key Changes You Need to Know
1.1 Mandatory TDR for All SINs (The Biggest Change)
The most impactful update in Refresh 31 is the mandatory adoption of Transactional Data Reporting (TDR) across all Special Item Numbers (SINs).
This fundamentally changes the pricing framework:
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Eliminates reliance on:
- Basis of Award (BOA)
- Price Reductions Clause (PRC)
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Removes CSP-1 and all non-TDR references
What this means:
Contractors are no longer tied to traditional commercial sales practices for pricing compliance. Instead, GSA shifts toward transactional visibility.
New Mandatory TDR Data Elements
Several data fields are now required (including previously optional ones):
- Ship Date
- Order Date
- Ship-to ZIP Code
- Federal Customer (Treasury Code)
- Cloud Service Type (for Cloud SINs)
- UCID (for catalog-based offerings)
- Order Type
- Order Discount (in limited cases)
- Worksite (services only)
New Reporting Requirements
Additional documentation must now be submitted:
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PWS/SOW/SOO uploads for:
- Fixed-price service orders over $1M
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Invoices and Bill of Materials (BOM) for:
- Highly Configurable Products (HCP)
- Configurable Services (CS)
Transition Rules
- Contractors must accept the TDR mass modification within 90 days
- TDR reporting begins the next reporting quarter after acceptance
- PRC liability ends once TDR is adopted
1.2 SCP-FSS-001 Updated
The Solicitation Provision SCP-FSS-001 has been streamlined to reflect:
- Mandatory TDR implementation
- Updated pricing structure
- Simplified guidance for contractors
1.3 Startup Springboard Now Restricted
The Startup Springboard program is now limited in scope:
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Available only under FASt Lane (IT category)
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Requirements include:
- IT SIN eligibility
- Agency sponsorship
- Alignment with federal IT initiatives
1.4 Expansion of Order-Level Materials (OLM)
OLM usage has been significantly expanded:
- Can now be used like any other SIN
- No longer restricted to subcategories
- Reduced reliance on Open Market Items
Bottom line: More flexibility—but within a structured framework.
1.5 New “Out-of-Scope” Restrictions
GSA has clearly defined items that are no longer allowed under MAS:
- Refurbished or reconditioned items (except toner)
- Automotive parts
- Toys, non-specialized clothing, sporting goods
- Food (except non-perishable under SIN 311423)
- Musical instruments and promotional items
2. Clause Changes
2.1 Added Clauses (Major Expansion)
Refresh 31 introduces a wide range of new compliance clauses, particularly around labor and regulatory requirements:
- Service Contract Labor Standards
- Minimum Wage (Executive Order 14026)
- Paid Sick Leave
- Copeland Act
- Subcontracting (FAR 52.244-6)
- Environmental regulations (e.g., ozone-depleting substances)
GSAR updates include:
- Industrial Funding Fee (IFF)
- Price Reductions
- Contract Modifications
2.2 Updated Clauses
Key clause updates include:
- Small Business Subcontracting Plan (new alternate version)
- Child Labor Clause (updated for 2026)
- Security Prohibitions Clause
- Apprentices and Trainees provisions
2.3 Deleted Clause
- Removed: FAR 52.204-27 (ByteDance/TikTok prohibition)
MAS Refresh 31 represents a clear move toward greater transparency, standardized reporting, and reduced pricing complexity. While the shift away from PRC and BOA reduces certain compliance burdens, the introduction of mandatory TDR significantly increases reporting expectations.
For contractors, success will depend on:
- Adapting internal systems for TDR compliance
- Strengthening data accuracy and reporting processes
- Understanding new documentation and scope limitations
What are your thoughts on MAS Refresh 31? Drop your opinions, concerns, suggestions, or questions in the comments. Our team will be happy to respond and help you prepare for what’s ahead.