When Was GSA Refresh 27 Released?
GSA released Refresh 27 of the GSA Multiple Award Schedule (MAS) solicitation on June 26, 2025. Refresh 28 is already in the works and could be released in August.
Refresh 27 Changes
Refresh 27 is packed with several significant changes, which are detailed below. In addition to the changes below, Refresh 27 incorporates clause and provision updates, as necessary, through Federal Acquisition Circular (FAC) 2025-04 and GSAR Change 199, excluding GSAR Change 187.
- TDR: Expanded & Mandatory
- Retired SINs
- Out of Scope Items
- Letter of Supply Requirements
- Resubmission Waiting Period
- Product Option Clarification
- Service Contract Labor Standards
- Price Proposal Templates (PPTs)
- Large Category Notes
- Subcategory/SIN Specific Changes
TDR Expanded & Mandatory
GSA conducted the first significant expansion of Transactional Data Reporting (TDR) almost a year ago with Refresh 22. Refresh 27 not only expanded TDR to 62 additional Special Item Numbers (SINs), but switched the program from optional to mandatory participation. As of Refresh 27, if your contract includes any TDR SIN, you are required to opt-in to TDR by September 30, 2025, if you have not elected to do so already.
Below is a list of the 62 SINs that are now TDR, view the complete list of mandatory TDR SINs here.
Retired SINs
Refresh 26 included the removal of 32 Special Item Numbers from the GSA MAS Contract. Refresh 27 pushed ten more SINs into retirement.
The offerings covered under 6 of the 10 newly retired SINs can be placed under other GSA MAS SINs, while the other 4 SINs must now be sold under other procurement channels, such as the Commercial Platforms or Open Market. The chart below lists each of the retired SINs and the procurement channel that can now be used to sell the SIN offerings.
Out of Scope Items
As of Refresh 27, the following items are now listed as “Out of Scope”. These items are in addition to remanufactured items (except toner), automotive parts, personal hygiene items, and fully assembled rotary-wing or fixed-wing aircraft, which were included as out of scope starting in Refresh 26.
- Books and publications (except technical publications and reports on SIN 511120)
- Children’s toys, dolls and games
- Promotional products
- Sporting goods
- General clothing items (except workwear under SIN 3152, uniforms under SIN 315210 and protective apparel under SIN 339113PA)
- Swimming pool equipment and supplies
- Musical instruments
- Customizable awards, medals and ribbons
Letter of Supply
Companies that want to sell products on the GSA Contract they do not manufacture themselves must be authorized by the manufacturer to distribute those products. Up until this latest refresh, companies had to provide Letter of Supply (LOS) documentation to GSA or be listed as an authorized distributor on GSA’s Verified Products Portal (VPP).
Now, the requirement to submit Letter of Supply documentation with a proposal or modification is only applicable to products under the IT Large Category or Printing and Photographic Equipment Subcategory.
A few important notes:
- Contractors are not allowed to sell products under their GSA Contract if they are not the manufacturer and are not authorized by the manufacturer. This remains true regardless of the Large Category or Subcategory.
- According to GSA, “if the manufacturer of the products that you offer participates in VPP, the manufacturer must list your company as an authorized reseller.”
- While a contractor may not be required to submit LOS documentation with their initial proposal or modification submission, Contracting Officers may still request that information.
Resubmission Waiting Period
GSA now has a 24-month waiting period to resubmit a proposal if your contract was cancelled or allowed to expire due to non-compliance, which includes no or low sales. This is a change from the previous 12-month period, which had also allowed an exception for low sales and a proposal for different SINs.
| Reason for Contract Cancellation/Expiration | SINs Included in New Offer | Required Waiting Period to Resubmit |
| Low Sales | Same as Cancelled Contract | |
| Low Sales | Different from Cancelled Contract | |
| Non-Compliance | Same as Cancelled Contract | |
| Non-Compliance | Different from Cancelled Contract |
Product Option Clarification
Refresh 27 added language to clarify that when including products with accessories or options on the GSA Contract, product options cannot be capable of functioning as a stand-alone item.
Service Contract Labor Standards
Refresh 27 incorporated updated Service Contract Labor Standards (SCLS) Wage Determinations.
Price Proposal Templates (PPTs)
While there were only minor changes to the Products Price Proposal Template, all PPTs were updated to be titled with “Refresh 27”.
Large Category Notes
Applicable to All Large Categories
Refresh 26 added a note regarding Artificial Intelligence/Machine Learning (AI/ML) restrictions to the IT Large Category. Refresh 27 expanded that restriction to all Large Categories. The following language is now in all Large Category attachments:
AI/ML Model Training Restrictions: The use of Government data for the purpose of training Artificial Intelligence/Machine Learning (AI/ML) models and systems is prohibited without explicit written authorization from the ordering activity contracting officer.
Definition: Government data means any information, (including metadata), document, media, or machine-readable material regardless of physical form or characteristics that is created or obtained by the Government, or a contractor on behalf of the Government, in the course of official Government business.
The latest refresh also added the following notes to each Large Category attachment:
Discontinuation of Offerings Based on Revoked Climate-related Executive Orders: In accordance with Section 4(e) of E.O. 14154, E.O.14148, and E.O. 14236, products or services associated with revoked E.O.’s (e.g., E.O.14057, E.O. 13990, and E.O. 14096) that do not have a statutory basis are excluded from the scope of the MAS program. This includes offerings related to the social cost of greenhouse gas emissions, social governance, environmental justice, and corporate social responsibility. Products and services supported by statutory authority remain within the scope of the MAS program.
Executive Order on Ending Radical and Wasteful Government DEI Programs: In accordance with E.O. 14151, Ending Radical and Wasteful Government DEI Programs and Preferencing, dated January 20, 2025, E.O. 14173, Ending Illegal Discrimination And Restoring Merit-Based Opportunity, dated January 21, 2025, and Fact Sheet: President Donald J. Trump Protects Civil Rights and Merit-Based Opportunity by Ending
Illegal DEI, dated January 22, 2025, which “terminates “diversity, equity, and inclusion” (DEI) discrimination in the federal workforce, and in federal contracting and spending”, any products, services, or solutions that violate the aforementioned provisions of the Executive Order are excluded from the scope of the MAS program.
Subcategory/SIN Changes
Refresh 27 updates also impact the Subcategories and SINs listed below:
Facilities
- SIN 561210FAC – Facilities Maintenance and Management
- The SIN description was edited to remove the language, “Services can be offered or ordered individually or in combination.”
- The SIN instructions were expanded to state, “GSA will not award MAS contracts to offerors only offering service types such as janitorial, plumbing, and electrical, which can effectively be performed by contractors who provide Complete Facilities Maintenance. The only standalone services allowable under SIN 561210FAC will be for offerors performing HVAC services (technical response must show experience in Boilers, Chillers, Refrigeration, etc.), Maintenance of Fire Alarm Systems and Maintenance of Fire Suppression Systems; and/or Elevator/Escalator Inspection Service and Elevator/ Escalator Maintenance Service.”
- The following SIN Subgroups were removed:
- Janitorial Services
- Maintenance of Fuel Facility
- Maintenance of Utilities
- SIN 322291 – Restroom Products
- The FOB Note was expanded and now includes clarification that the note is applicable to the SIN level and not the entire GSA Contract.
Furniture
- SIN 33721P – Packaged Office Furniture
- The SIN was renamed, “Packaged Furniture.”
- SIN 339920S – Sporting Goods, Fitness Equipment, and Supplies
- The SIN was renamed, “Fitness Equipment, Outdoor Gear and Related Items.”
- The SIN description was changed to the following: “Includes all fitness equipment (including fitness technology), smart exercise equipment, fitness supplies such as weight benches, treadmills, wearable fitness technology, fitness trackers, and related fitness applications. Also includes equipment and accessories specifically designed for personnel operating in outdoor environments.”
- The SIN Instructions now include exclusions for:
- Promotional products, writing tools, office supplies, personal accessories, drinkware, tableware, bags, carrying cases, and any products suitable for engraving, imprinting, or customization. This includes, but is not limited to, pens, rulers, tape measures, magnets, key tags, luggage tags, pocket tools, ice scrapers, mugs, glassware, planners, portfolios, calculators, briefcases, computer accessories (e.g., mouse pads, wrist rests), and similar items.
- Protective sports gear and apparel, including items for baseball, basketball, billiards, boxing, wrestling, martial arts, football, golf, gymnastics, handball, racquetball, hockey, skiing, soccer, tennis, track and field, volleyball, shuffleboard, lacrosse, bowling, golf, archery, and related items such as sport pumps, inflators, and air pumps.
- Equipment and supplies for swimming pools, spas, therapy spas, above-ground pools, pool resurfacing, pool cleaning services, and hot tubs.
Office Management
- Media Products Subcategory
- The Media Products Subcategory was deleted, since the only SIN under this Subcategory, SIN 511130 Books and Pamphlets, was retired with Refresh 27.
- Printing and Photographic Equipment Subcategory
- The Subcategory instructions were updated to clarify the Letter of Supply/Authorization issued by the Original Equipment Manufacturer (OEM) must cover the proposed contract period of performance.
- SIN 511120 – Periodicals, Subscriptions, Online Book Selling and Lending Library Services
- The SIN was renamed, “Technical Publications and Industry Reports.”
- The SIN description was changed to: “Technical publications, subscriptions, industry reports, scientific/technical journals, engineering publications, instructional manuals.”
- A note was added that the SIN excludes “periodicals, online book selling and lending library services, textbooks, educational materials, pamphlets, children’s books, and any other general use printed items such as: books, publications, or written materials, novels, guides, reference books and all other media services.”
Miscellaneous
- SIN 339999F – Flags, Banners, Pennants, and Related Products
- The SIN description was changed to state, “Includes all flags, banners, pennants, ceremonial and color guard equipment. This encompasses only military, state, and government official items, to include customization.”
- A SIN instruction note was added to exclude “promotional items, writing instruments, office supplies, personal accessories, drinkware, tableware, bags, carrying cases, and other items suitable for engraving, imprinting, or customization, including but not limited to pens, rulers, tape measures, magnets, key tags, luggage tags, pocket tools, ice scrapers, mugs, glassware, planners, portfolios, calculators, briefcases, computer accessories (e.g., mouse pads, wrist rests), and any similar products.
- SIN 3152 – Clothing
- The SIN was renamed, “Workwear Clothing.”
- The SIN description was edited to reflect the new SIN title.
- SIN 4PL – Fourth-Party Logistics (4PL) Supplies and Services
- The SIN description was revised to remove reference to Vendor-Owned/Vendor-Consigned Inventory Services (VCI).
Travel
- SIN 531 – Employee Relocation Solution
- The SIN’s Price Proposal Template has been revised to include a ‘Per Employee” unit of issue within the “531 Move Mgt” tab.
- The SIN specific requirements document was updated.
Need Help with TDR or Other GSA Contract Updates?
Whether you need help understanding and opting in to TDR, or making any other GSA Contract updates, we can help! For nearly 40 years, our contract experts here at FEDSched have been helping GSA contractors successfully meet their contract needs.