When Will Refresh 21 Be Released?
GSA Solicitation Refresh 21 was issued late on Tuesday, May 28, 2024.
What is Changing with Solicitation Refresh 21?
As usual, GSA Refresh 21 includes several Schedule-wide changes, as well as changes specific to Large Categories, Subcategories, and Special Item Numbers (SINs).
Among the administrative clean-up and clarifications, GSA rolled out a new IT SIN for credential service providers and new, optional TDR Data Elements. Refresh 21 also includes the incorporation of clause and provision updates, as needed, through Federal Acquisition Circular (FAC) 2024-05 and GSAR Change 179.
Overview of Refresh 21 Changes:
- Offer Instructions Update (Schedule-Wide)
- Examination of Records Note (Schedule-Wide)
- Large Category General Information (Schedule-Wide)
- New TDR Fields (Applicable to TDR Contractors)
- New IT SIN for Credential Service Providers
- Payment Guidance for IT SINs
- Updated Descriptions for Printing/Photo Equipment SINs
- Updated SIN-Specific Documents
Offer Instruction Updates
If your company held a GSA MAS Contract that was cancelled or allowed to expire due to low sales or non-compliance there are additional requirements you must meet to obtain a new GSA MAS Contract. Refresh 21 adds language that specifies what requirements are applicable to joint venture entities and joint venture partners.
Examination of Records Note
The Examination of Records, Clause 552.238-83, provides GSA the right to review “books, documents, papers and records of the contractor involving transactions related to this contract for overbillings, billing errors, compliance with contract clauses.”
Refresh 21 adds the following note to this clause:
The types of books, documents, papers and records shall include but not be limited to:
- Eligible users of the GSA Sources of Supply and Services, as defined by OGP 4800.2I and/or subsequent orders;
- Basis of Award customers, 552.238-81 Price Reductions, and 552.238-80 Industrial Funding Fee and Sales Reporting;
- Verifying CSP-1 Form accuracy and completeness;
- GSA MAS Contractor Team Arrangements (CTAs); and
- Authorized Dealers incorporated into the MAS contract by the Contracting Officer
Large Category General Information
As of Refresh 21, each of the twelve Large Category Attachments includes a new “General Information” section. While the General Information section may vary across the Large Category attachments, all Large Category attachments will include the following note regarding prohibited items:
“Drones/Unmanned Aircraft Systems: GSA will not award any Drones/Unmanned Aircraft Systems (UAS), as defined in 49 USC Ch. 448, in response to this Large Category except those drones approved by the Department of Defense (DoD) Defense Innovation Unit (DIU) through its Blue sUAS Program.
Firearms and Ammunition: GSA will not award weapons such as firearms, live ammunition, explosives, and artillery weapons under this Solicitation. This also includes components that are solely used to produce functional weapons. Components that will not be awarded under this Solicitation include, but are not limited to, barrels, chambers, bolts, trigger groups, stock, magazines, rockets, grenades, grenade launchers, mines and mortars, cases, primers, powder, and projectiles.
This exclusion does not apply to non-lethal ammunition types intended to be used for training, safety, and marking purposes.”
New TDR Fields
If your company holds a Transactional Data Reporting (TDR) eligible SIN and has elected to participate in TDR, you are required to report on 12 transactional data elements. Refresh 21 lays out four additional fields that you may report on an optional basis starting July 1, 2024. While the long-term plan is to make the fields below mandatory, reporting will be optional for at least six months for GSA to make assessments.
- Order date – this field is optional for products only
- Ship date – this field is optional for products only
- Zip Code shipped to – this field is optional for products only
- Federal Customer -Treasury Agency Code – optional for both products and services
The biggest take-away from this change is that it is part of GSA’s plan to address data gaps and to potentially expand TDR to 60 or more additional product SINs in the future. If you’re not familiar with TDR, you can learn more here.
New IT SIN for Credential Service Providers
Not to be confused with Cloud Service Providers, the CSP in GSA’s newest Special Item Number (SIN), 541519CSP, stands for Credential Service Providers. Learn more about SIN 541519CSP here.
Payment Guidance IT SINs
The new General Information section of the IT Large Category includes a lengthy note detailing “Guidance on Payment for Software Licenses Delivered via Software as a Service (SaaS).” This section provides a brief background on SaaS software delivery and licensing. The main purpose of the guidance is to distinguish between advance payment, which is generally prohibited, and upfront payment, which is generally allowed. Below is an excerpt:
“Upfront payment for software licenses delivered or accessed via SaaS is not considered advance payment. The central distinction is the contemporaneous access as long as the purchase meets the following criteria:
- Access to the software is granted contemporaneously with payment (i.e., delivery of the
license is made contemporaneously with payment); - The license is acquired on a fixed-price or fixed-price with economic price adjustment basis even if other portions of the task order or contract are not fixed price;
- The license is priced at a single seat, multi-seat, unit, or subscription price covering a fixed term, defined as “a limited period of time”;
- The license’s pricing/billing model allows for no utilization or consumption metric other than quantity to affect the costs incurred over the negotiated term;
- The license does not require any upfront payment other than the fixed seat, unit, or subscription cost as a prerequisite for access or a pricing discount; and
- Within end user or other license agreements, the license service is continuous and uninterrupted for the negotiated term of access to the license.
All other cloud computing services (i.e., IaaS, PaaS, SaaS) and professional services must be paid in arrears in accordance with 31 U.S.C. § 3324 and 41 U.S.C. § 4505.”
The solicitation instructions regarding billing for the following SINs have been moved to the General Information section:
- SIN 518210C, Cloud Computing & Cloud Related IT Professional Services
- SIN 518210FM, Financial Management Quality Service Management Office (FM QSMO) Core Financial Management (FM) Solutions
- SIN 54151ECOM, Electronic Commerce and Subscription Services
- SIN 541519ICAM, Identity, Credentialing and Access Management (ICAM)
- SIN 561422, Automated Contact Center Solutions (ACCS)
- SIN 517410, Commercial Satellite Communications Solutions (COMSATCOM)
- SIN 517312, 517312 Wireless Mobility Solutions
Updated Descriptions for Printing/Photo Equipment SINs
The following SINs under the Printing and Photographic Equipment Subcategory have been revised to include multifunction printers (MFP) and multifunction devices (MFD):
- SIN 333316C, Copiers and Digital Duplicating Equipment
- SIN 333316CPC, Cost-per-Copy Plan for Copiers (to include Analog, Digital, Multifunctional and Engineer Copiers)
- SIN 333316F, Flat Rate Monthly Fee for Copiers (to include Analog, Digital, Multifunctional and Engineer Copiers)
- SIN 333316OS, Overseas Copiers and Supplies
- SIN 532420C, Copier Rental Solutions
- SIN 532420LC, Operating Lease Plan For Copiers
- SIN 532420LTOP, Lease to Ownership Plans (LTOP) Copier
Updated SIN-Specific Documents
If your company is in the process of pursuing any of the Special Item Numbers (SINs) listed below, make sure to download the most recent version of the SIN-specific templates and/or documents, as these have been updated with Refresh 21.
- SIN 518210C, Cloud Computing and Cloud Related IT Professional Services
- SIN 541990IPS, Data Breach Response and Identity Protection
- SIN 561510, Travel Agent Services
To download the most recent documents, go to GSA’s page here, scroll down to the SIN look-up table, and type your SIN number in the “Filter table” search box. Any SIN-specific templates or attachments will be linked in the Resources column.
Get Expert Help to Navigate GSA Changes
Our team here at FEDSched has been helping companies understand and expertly navigate changes at GSA since 1986. Contact us today to discuss your GSA MAS Contract needs!
