What’s Not Included
In case you’ve been tracking it, there are two previously announced changes that are still pending as of Refresh 33:
- AI Clause (GSAR 552.239-7001): First proposed in March 2026 for Refresh 31, then deferred to Refresh 32, it is now expected to be included in Refresh 34 next month.
- JV Program Changes: Changes proposed in Refresh 32 would have limited companies to holding a GSA contract under only one Joint Venture (JV). For now, the existing rules apply, which allow a contractor to be a member of up to three joint ventures that hold a GSA MAS Contract.
Refresh 33 has a medium impact on GSA contractors, driven by the addition of Supply Chain Risk evaluation and monitoring requirements. As per usual, existing GSA MAS Contract holders will have 90 days to accept the associated mass modification.
- Supply Chain Risk Terms (Schedule-Wide Change)
- Springboard/FASt Lane Change (Schedule-Wide Change)
- Product Substitutions Change (Schedule-Wide, Product-Specific Change)
- Miscellaneous Changes
- Other SIN-Specific Changes
Supply Chain Risk Terms (Schedule-Wide Change)
Refresh 33 introduced two Supply Chain Risk-related terms (detailed below), along with language detailing the Supply Chain Risk evaluation process. While the supply chain requirements are not entirely new, Refresh 33 formalizes and standardizes the language. Essentially, prospective and existing contractors are subject to supply-chain-risk vetting at award and continuously during performance.
Newly Incorporated Supply Chain Risk Related Terms:
- 552.540-70 (Notice of Evaluation of Supply Chain Risk)
- 552.540-71 (Supply Chain Risk Monitoring)
The solicitation now states, in order to evaluate Supply Chain Risk, the government may:
- Use a variety of sources to review corporate ownership, control, affiliation, and subsidiary relationships
- Based upon review, identify potential connections to entities prohibited or restricted by applicable law or regulation
- If it identifies supply chain risks that can’t be reasonably mitigated:
- Deny award of a contract
- Remove offerings from a contract
- Not extend contract performance
- Cancel or terminate a contract
As advised in the solicitation, contractors should pay particular attention to accuracy (as they should always) and transparency regarding “corporate structure and ownership, product country of origin and authorization (e.g., manufacturer status or Letter of Supply), and applicable compliance representations.”
Springboard/FASt Lane Change
(Schedule-Wide Change)
GSA’s Startup Springboard program is the only path to obtain a GSA MAS Contract for companies with less than 2 years in business. Earlier this year, GSA sharply reduced the number of companies eligible for Springboard by requiring participants to also qualify for FASt Lane, which at the time was limited to the IT Large Category.
Refresh 33 partially walks back that restriction through a change to FASt Lane and an added note in the solicitation. The solicitation now explicitly states that the Startup Springboard program “is available across all Large Categories; however, participation remains limited to eligible FASt Lane participants only.”
GSA also updated its FASt Lane page and Eligibility Document this month to allow new offers under any Large Category. However, FASt Lane modifications are still limited to IT offerings.
Keep in mind, with FASt Lane now open to new offers under any Large Category, the biggest qualify hurdle contractors will face is obtaining a “written request from a federal agency ordering activity that demonstrates a compelling need for your company to participate in FASt Lane to support the agency’s requirements.”
Miscellaneous Changes
Refresh 33 also included:
- Via Class Deviation CD-2026-03, removal of the carve-out that previously exempted Federal Prison Industries, Inc. and AbilityOne Participating Nonprofit Agencies from complying with the Trade Agreements Act (TAA). (Schedule-Wide, Product-Specific)
- Language giving GSA the right to reject customer references from an affiliate (GSA previously reserved the right to reject references from partially or wholly owned entities of the offeror.)
- Integration of the most recent wage determinations for Service Contract Labor Standards (SCLS)
Other SIN-Specific Changes
Facilities Large Category
- SIN 238160 Roofing Products and Services Solutions → SIN Description revised to allow for materials only, services/labor only, or a comprehensive requirement for both.
- SIN 532490P Lease/Rental of Pre-Engineered/Prefabricated
Buildings and Structures → Multiple Changes- SIN Description expanded to allow for additional structure types
- New SIN instructions and note
- Modified the following SIN Subgroup to add Showers:
- Lease/Rental of Pre-Engineered/Prefabricated Restrooms, Showers, and Utility Rooms
- New SIN Subgroup:
- Turnkey Base Camp Facilities and Operational Support Products or Services
As GSA puts it, the SIN 532490P update “clarifies the scope of SIN 532490P to include general temporary facility needs. It also formalizes the inclusion of turnkey base camp facilities and integrated operational support services, such as laundry and housekeeping, within the scope.”
IT Large Category
- SIN 517312 Wireless Mobility Solutions → Three New Subgroups:
- Managed Mobility Services
- Managed Wireless Service
- Enterprise Access, Connectivity, and Transport Services
Miscellaneous Large Category
- SIN 4PL Fourth-Party Logistics (4PL) Supplies and Services → SIN Description was updated to allow for bottled water despite food, candy, and drinks being listed as “Out of Scope Items”
- SIN 238910 Installation and Site Preparation Services → SIN Instructions were updated to consolidate the ordering requirements and add conditions (including separate pricing) to ensure ancillary services, incidental products, and equipment rentals are always tied to, and in direct support of, a qualifying purchase
Travel Large Category
- SIN 531 Employee Relocation Solution → Revised Statement of Work (SOW)
- SIN 561510 Travel Agent Services → Revised SOW and Price Proposal Template (PPT)