Forming an “All Small” Joint Venture (JV) has always been a strategic move for small businesses looking to scale their capabilities and compete for larger opportunities under the GSA Multiple Award Schedule (MAS). By combining strengths, resources, and experience, these partnerships allow smaller firms to access contracts that would otherwise be out of reach. However, with the introduction of MAS Refresh 31, the expectations around past performance have evolved significantly, and this shift is something GSA MAS prospective contractors/applicants and onboarding specialists/consultants need to fully internalize.
To understand the impact of this change, it helps to briefly revisit how things worked under MAS Refresh 30. At that time, joint ventures that did not have their own past performance could rely on their individual partners to demonstrate capability. In mentor-protégé or socioeconomic joint ventures, the requirement was relatively lenient for the less experienced partner, who only needed to provide minimal documentation such as a single CPARS report or a customer reference supported by a Past Performance Questionnaire. The more experienced partner would typically shoulder the majority of the burden, ensuring that the overall proposal met the required standards. For standard “All Small” joint ventures, the absence of clearly defined guidance led many proposal teams to adopt a similar approach, often relying heavily on one dominant partner with a strong federal track record to carry the past performance section.
MAS Refresh 31 changes this dynamic in a fundamental way by introducing a clearly defined and stricter requirement specifically for “All Small” joint ventures. The updated solicitation makes it explicit that every small business partner within the JV must independently demonstrate past performance. This means that each partner is now required to verify at least one CPARS report in eOffer, or alternatively, submit a customer reference along with a completed Past Performance Questionnaire if a CPARS report is not available. The flexibility that once allowed one strong partner to compensate for others is no longer applicable.
This shift becomes particularly clear when viewed through a practical example. Consider a joint venture formed by three companies: Company A, Company B, and Company C. Under previous practices, Company A’s extensive portfolio of successful federal contracts and multiple CPARS reports could have been sufficient to support the entire JV’s past performance submission. However, under Refresh 31, that approach would not meet compliance standards. While Company A can still contribute its strong record, Company B and Company C must now independently provide their own documentation. If Company C, as a new entrant, lacks both CPARS reports and credible customer references, the entire proposal risks rejection regardless of how strong the other partners may be.
For proposal teams, this change is more than just a procedural update; it represents a shift in how joint ventures must be evaluated and prepared from the very beginning. The emphasis is no longer on the collective strength being anchored by a single dominant partner, but rather on the individual readiness of each participant. This requires a more disciplined approach during the onboarding phase, where every partner’s ability to meet past performance requirements must be assessed early and thoroughly. It also means that client expectations need to be managed more carefully, ensuring that all parties understand their responsibilities and the documentation they must provide.
Ultimately, MAS Refresh 31 raises the bar for “All Small” joint ventures by enforcing a more equitable distribution of accountability among partners. While this may introduce additional challenges, it also encourages stronger, more balanced collaborations where each entity contributes meaningfully to the proposal. For those who adapt their processes accordingly, this change is not just a compliance hurdle but an opportunity to build more resilient and credible joint ventures in the long run.
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