GSA plans to issue Refresh 4 of the Multiple Award Schedule (MAS) Solicitation on August 13, 2020. Companies that hold a GSA MAS Contract will receive a mass modification (mod) to incorporate Refresh 4 changes into their contract.
While contractors typically have 90 days to accept a mass mod, you should accept the Refresh 4 mass mod as soon as possible. Effective August 13, 2020, companies cannot accept orders under a GSA MAS Contract until accepting the Refresh 4 mass mod. Why? It all has to do with prohibited telecommunications, the Federal Acquisition Regulation (FAR), and Section 889 of the FY 2019 National Defense Authorization Act (NDAA).
GSA Contract holders should also be aware of the new process for signing mass modifications that went into effect this month. Contractors no longer need a digital certificate or a PIN to sign mass mods. The system now uses a two-step, multi-factor authentication (MFA) process that only allows authorized negotiators with signing authority to sign mass mods. It is important to note, you will still need a digital certificate to make changes and update your GSA contract through the eMod system, so please do not let your digital certificate lapse. You can find more information on the MFA process, including a User Guide on GSA Interact here.
GSA MAS Solicitation Refresh 4 Changes
Below are a few of the significant changes incorporated by Refresh 4.
- Prohibited Telecom – You may recall accepting a mass mod last year that, in essence, required your company to certify that you do not provide prohibited telecom equipment in the performance of any government contract. That was Part A of Section 889 of the FY 2019 NDAA. The Refresh 4 mass mod is now incorporating Part B, which requires you to certify that you don’t use any prohibited telecom whether or not it’s in relation to a government contract. Download GSA’s overview of Section 889 Part B here and the FAQ here.
- Past Performance Requirements – GSA is making a welcome change to the past performance requirement. Previously companies that could not meet the Contractor Performance Assessment Reporting System (CPARS) or Open Ratings requirements were required to submit three to five customer references. GSA would then ask those references to complete a past performance questionnaire. This process led to delays in the proposal review and, in some cases, rejections if customer references failed to respond to GSA. Moving forward, companies will be responsible for contacting their references and asking them to complete the Past Performance Questionnaires (PPQ). The completed PPQ should be included in your proposal submission, which should reduce review times and eliminate rejections due to non-responsive references.
- Deletion of Two SINs – Companies will no longer be able to offer used/refurbished IT equipment or the rental of IT equipment through the GSA MAS Contract. Refresh 4 will remove these two Special Item Numbers, detailed below, from the MAS Solicitation. GSA acknowledged they received industry feedback requesting that SIN 33411REF remain active. However, they decided to move forward with the retirement of the SIN, despite industry requests, citing supply chain vulnerabilities among a few other factors.
- SIN 132-4/532420R Daily/Short Term Rental of IT Equipment
- SIN 132-9/33411REF Purchase of Used or Refurbished Equipment
- AbilityOne Products – Language will be updated to clarify that products considered “Essentially the Same” (ETS) as products offered through the AbilityOne Program, may not be offered through the GSA MAS Contract, even if the contract is held by an AbilityOne Distributor.
- Removal of Clause 52.222-17 Nondisplacement of Qualified Workers – A clause that required service contractors and their subcontractors to offer employees of the predecessor contractor and its subcontractors a right of first refusal of employment for positions that they qualified for has been deleted.
You can view GSA’s post regarding the changes here on Interact. In the meantime, subscribe to our alerts and quarterly newsletter to stay up to date, or contact us to discuss how Federal Schedules, Inc. can help you navigate the changes.
