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9/4/2025

GSA Refresh 29: Revised EPA Clause

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GSA Refresh 20

GSA Refresh 29 Release Date

GSA released Refresh 29 of the GSA Multiple Award Schedule (MAS) solicitation on August 28, 2025.

Refresh 29 Changes

The main highlight of Refresh 29 is the rollout of a new Economic Price Adjustment (EPA) clause. In addition to the changes below, Refresh 29 incorporates clause and provision updates from GSAR Change 187. Also, be sure to download the latest modification guide, which includes updated instructions for EPA modifications.

  • New EPA Clause
  • Note Regarding Catalogs
  • Retired SBSA SINs
  • Temporary Reprieve for One Out of Scope Item
  • Price Proposal Templates (PPTs)
  • Subcategory/SIN Specific Changes
Get Refresh Summaries Delivered to Your Inbox

New EPA Clause

After nearly a year long wait, the new Economic Price Adjustment (EPA) clause is now replacing legacy EPA clauses. The Modification Guide and “Instruction Applicable to All Offerors” have also been updated in accordance with the new EPA clause.

The legacy EPA clauses placed restrictions on when, how often, and how much a contractor could increase their GSA pricing. The new EPA clause, which you can review below, permanently removes certain EPA restrictions that had been suspended since 2022 in response to inflation and changing market conditions.

In addition to removing contract-wide time-based price increase restrictions and ceiling percentage limits, the new EPA clause requires contractors to establish a method which may include the mechanism to be used, timing, frequency, or limits. The mechanisms are detailed below.

New EPA Clause Mechanisms Include:

  1. Adjustments based on fixed escalation rates
  2. Adjustments based on a market index or other basis
  3. Adjustments based on established pricing
    • Pricing must be dated, existing, standalone, and not prepared solely for the government
  4. Adjustments based on unforeseeable significant changes in market conditions

What Does this Mean for Existing GSA Contract Holders?

The new EPA Clause, 552.238-120, will be incorporated into existing GSA MAS Contracts and will replace the clauses below when the Refresh 29 mass modification is accepted.

New EPA Clause Replaces:

  • 552.216-70 Economic Price Adjustment – FSS Multiple Award Schedule Contracts (Sep 1999) (Alternate I – Sep 1999)
  • 552.216-70 Economic Price Adjustment – FSS Multiple Award Schedule Contracts (Sep 1999) (Deviation II – Jul 2016)
  • I-FSS_969 Economic Price Adjustment – FSS Clause Multiple Award Schedule (Oct 2014)
  • I-FSS_969 Economic Price Adjustment – FSS Clause Multiple Award Schedule (Oct 2014)(Alternate II – Jul 2016)

All existing GSA contractors will also need to submit a “Revise Terms and Conditions” modification to implement the EPA method/mechanism in accordance with the new GSAR 552.238-120. The timing of this modification will vary. However, at minimum, contractors must submit the modification prior to a contract renewal option or the submission of any addition or EPA modifications.

What Does this Mean for Prospective GSA Contract Holders?

Moving forward, new proposals should include the methods and mechanisms for economic price adjustments that are allowed under the new clause. Companies that have a proposal submitted, but not awarded, will likely need to negotiate this as well.


Note Regarding Catalogs

Refresh 29 includes the addition of the following note in relation to 552.239-103 Electronic Commerce:

Note: Regulation 552.238-103
Note: All contractors are required to comply with GSA’s established catalog submission and maintenance rules to ensure accurate and complete electronic commerce representation. Detailed instructions and guidance can be found in the FAS Catalog Platform (FCP) Help Page at https://catalog.gsa.gov/help.


Retired SBSA SINs

Refresh 29 completes the process, which was started with Refresh 24, of removing small business set-aside (SBSA) Special Item Numbers (SINs) from the GSA MAS Contract. Please note, small business set-asides are still allowed under the GSA MAS Contract. Learn more about the change here.


Temporary Reprieve for One Out of Scope Item

Refresh 26 established a list of out of scope items that could not be offered on the GSA Schedule. One of those items included fully assembled rotary-wing aircraft (helicopters). While fixed-wing aircraft is still considered out of scope, GSA is temporarily allowing helicopters under SIN 336413 until they can establish an alternative acquisition strategy.


Price Proposal Templates (PPTs)

While Price Proposal Template changes are typical of all recent refreshes, Refresh 29 is laying the groundwork for transitioning all GSA MAS Contracts to GSA’s Federal Acquisition Service (FAS) Catalog Platform (FCP).

Companies that currently hold a GSA MAS Contract should continue to use the file type they’ve been using for modifications, whether that be an FCP file or legacy PPT. However, moving forward, companies submitting a proposal to obtain a new GSA MAS Contract must use the FCP Product File and/or FCP Services Plus File unless their proposal includes any of the following SINs:

  • SIN 531 – Employee Relocation Solution
  • SIN 531110 – Long Term Lodging
  • SIN 561599L – Lodging Negotiations and Management Services
  • SIN 561510 – Travel Agent Services
  • SIN 561599 – Travel Consulting Services
  • SIN 4PL – Fourth-Party Logistics (4PL) Supplies and Services
  • SIN 485 – Ground Transportation
  • SIN 532112 – Leasing of Passenger Cars, SUVs, Vans, and Light Trucks
  • SIN 492110 – Package Delivery and Freight Trucking
  • SIN 492210 – Local Courier Delivery Services
  • SIN 532111 – Automotive equipment rental and leasing, Rental Supplemental Vehicle Program (RSVP)
  • SIN 481211O – Air Charter Services – Owner Operated
  • SIN 481211B – Air Charter Services – Brokers

Subcategory/SIN Changes

Refresh 29 updates impact the Subcategories and SINs listed below:

Furniture

  • SIN 33712 – Complete Daycare, Preschool and Classroom Solutions
    • The SIN description was revised to remove “toys” as toys were made out of scope in Refresh 27.

IT

  • SIN 518210C – Cloud Computing and Cloud Related IT Professional Services
    • GSA added the following to the SIN description, “Exception for Software as a Service (SaaS): Proposed offerings do not have to meet the first of the five NIST cloud characteristics in NIST SP 800-145; the first NIST cloud characteristic is: ‘On-demand self-service. A consumer can unilaterally provision computing capabilities, such as server time and network storage, as needed automatically without requiring human interaction with each service provider.’ It is not a SIN 51810C requirement that the SaaS customer be able to (de)provision SaaS access/licenses unilaterally with no human interaction with the SaaS provider.”
  • SIN 54151HACS – Highly Adaptive Cybersecurity Services (HACS)
    • The HACS SIN instructions, Section 1d states labor categories should be in alignment with NICE Framework. In response to an update of the NICE Framework, GSA updated this section to remove references to “work role IDs” and instead refer contractors to the most up-to-date NICE Framework.

Miscellaneous

  • GSA removed the following Subcategories because associated SINs were retired:
    • Awards Subcategory
    • Personal Hair Care Items Subcategory

Scientific

  • SIN 334515 – Diagnostic, Measuring and Testing Equipment
    • GSA removed the subgroup “Unmanned Aerial/Vehicle Systems/Drones for Operations Support, Data Collection, Analysis, Reporting, and Related Services.” These offerings should be placed under SIN 334220.

Security

  • SIN 334220 – Surveillance Systems, Wearable Body Cameras, and Vehicular Video
    • The SIN description has been expanded to include, “Unmanned Aircraft Systems (UAS)/Drones, along with associated replacement parts, accessories, and ancillary services such as training and installation, when offered as part of a total solution.”
  • SIN 33641 – Aircraft Armoring and Helicopter Equipment
    • GSA is temporarily reversing course on disallowing helicopters under SIN 336413.
    • The following has been added: “NOTE: Any unique technical specifications, regulatory requirements, or other terms and conditions applicable to aircraft or aircraft-related items are the responsibility of the ordering activity to identify and
      incorporate at the time of order placement.”

Need Help Navigating Changes and Contract Updates?

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Previous 552.216-70 Economic Price Adjustment

**Previous EPA Clauses**

552.216-70 ECONOMIC PRICE ADJUSTMENT – FSS MULTIPLE AWARD SCHEDULE CONTRACTS (SEP 1999) (ALTERNATE I – SEP 1999)

Price adjustments include price increases and price decreases. Adjustments will be considered as follows:

(a) Contractors shall submit price decreases anytime during the contract period in which they occur. Price decreases will be handled in accordance with the provisions of the Price Reductions clause.

(b) Contractors may request price increases to be effective on or after the first 12 months of the contract period providing all of the following conditions are met:

(1) Increases resulting from a reissue or other modification of the Contractor’s commercial catalog/price list that was used as the basis for the contract award.

(2) No more than three increases will be considered during each succeeding 12-month period of the contract. (For succeeding contract periods of less than 12 months, up to three increases will be considered subject to the other conditions of this subparagraph (b)).

(3) Increases are requested before the last 60 days of the contract period.

(4) At least 30 days elapse between requested increases.

(c) In any contract period during which price increases will be considered, the aggregate of the increases during any 12-month period shall not exceed SEE CLAUSE NOTE percent of the contract unit price in effect at the end of the preceding 12-month period. The Government reserves the right to
raise the ceiling when market conditions during the contract period support such a change.

(d) The following material shall be submitted with the request for a price increase:

(1) A copy of the commercial catalog/price list showing the price increase and the effective date for commercial customers.

(2) Commercial Sales Practices Format regarding the Contractor’s commercial pricing practice relating to the reissued or modified catalog/price list, or a certification that no change has occurred in the data since completion of the initial negotiation or a subsequent submission.

(3) Documentation supporting the reasonableness of the price increase.

(e) The Government reserves the right to exercise one of the following options:

(1) Accept the Contractor’s price increases as requested when all conditions of (b), (c), and (d) of this clause are satisfied;

(2) Negotiate more favorable discounts from the new commercial prices when the total increase requested is not supported; or,

(3) Remove the product(s) from contract involved pursuant to the Cancellation clause of this contract, when the increase requested is not supported.

(f) The increased contract prices shall apply to delivery orders issued to the Contractor on or after the
effective date of the contract modification.


552.216-70 ECONOMIC PRICE ADJUSTMENT – FSS MULTIPLE AWARD SCHEDULE CONTRACTS (SEP 1999) (DEVIATION II – JUL 2016)

Price adjustments include price increases and price decreases. Adjustments will be considered as follows:

(a) Contractors may submit price decreases anytime during the contract period in which they occur. Price decreases will be handled in accordance with the provisions of the Price Reduction Clause.

(b) Contractors may request price increases to be effective on or after the first 12 months of the contract period providing all of the following conditions are met:

(1) No more than three increases will be considered during each succeeding 12-month period of the contract. For succeeding contract periods of less than 12 months, up to three increases will be considered subject to the other conditions of this subparagraph (b).

(2) Increases are requested before the last 60 days of the contract period.

(3) At least 30 days elapse between requested increases.

(c) In any contract period during which price increases will be considered, the aggregate of the increases during any 12-month period shall not exceed SEE CLAUSE NOTE percent of the contract unit price in effect at the end of the preceding 12-month period. The Government reserves the right to
raise the ceiling when market conditions during the contract period support such a change.

(d) Documentation supporting the reasonableness of the price increase shall be submitted with the request for a price increase.

(e) The Government reserves the right to exercise one of the following options:

(1) Accept the Contractor’s price increases as requested when all conditions of (b), (c), and (d) of this clause are satisfied;

(2) Negotiate smaller increases when the total increase requested is not supported; or,

(3) Remove the product(s) from contract involved pursuant to the Cancellation Clause of this contract, when the increase requested is not supported.

(f) The increased contract prices shall apply to delivery orders issued to the Contractor on or after the effective date of the contract modification.


Note: Regulation 552.216-70
The EPA Ceiling Limit for this clause is hereby established as 4% for the Human Capital Category, 5% for the Professional Services Category, 5% for the Travel Category and 10% for all other Large Categories.

552.238-120 Economic Price Adjustment—Federal Supply Schedule Contracts.

Economic Price Adjustment—Federal Supply Schedule Contracts (Sep 2024)

(a) Definition. “Economic price adjustment method”, as used in this clause, means the agreed upon procedures by which pricing may be adjusted throughout the contract period to include, but not limited to, the mechanism(s) to be used to adjust pricing (e.g., adjustments based on established pricing), the pricing subject to adjustment, and any other requirements (e.g., timing, frequency, limits on increases).

(b) General. This contract provides for economic price adjustment (EPA) to contract pricing based on the established EPA method. EPA provides for the increase and decrease to stated contract pricing upon the occurrence of specified conditions described in the EPA method, such as market index changes or unforeseeable significant changes in market conditions.

(c) Exceptions. This clause does not cover—

(1) Adjustments based on statute, Executive Order, or regulation (e.g., Service Contract Labor Standards ( 41 U.S.C. chapter 67) and AbilityOne procurements ( FAR subpart 8.7));

(2) Adjustments based on a change clause (e.g., paragraph (c) of GSAR clause 552.212-4, Contract Terms and Conditions—Commercial Products and Commercial Services (FAR DEVIATION 52.212-4));

(3) Price reductions made under GSAR clause 552.238-81, Price Reductions;

(4) Adjustments based on GSAR clause 552.238-117, Price Adjustment-Failure to Provide Accurate Information; and

(5) Adjustments based on a contract clause that authorizes an adjustment based on specified actions or conditions.

(d) Economic price adjustment method. The EPA method may be revised through mutual agreement of the parties. In the event of a conflict between the EPA method and this contract, the contract shall control.

(e) Submission requirements. The Contractor shall submit EPA requests to the Federal Supply Schedule (FSS) Contracting Officer pursuant to the EPA method. EPA requests shall fully conform to the requirements of the EPA method and include sufficient information to support the request. The FSS Contracting Officer may request additional information from the Contractor.

(f) Contracting Officer responsibilities. The FSS Contracting Officer will—

(1) Review the EPA request to ensure conformance with the EPA method,

(2) Make a determination. The FSS Contracting Officer may use any information (e.g., market research) deemed necessary to support their determination. The FSS Contracting Officer may determine to—

(i) Accept the EPA request either in whole or in part,

(ii) Reject the EPA request either in whole or in part, or

(iii) Take any other action deemed to be in the best interest of the Government (e.g., negotiate a more favorable EPA).

(3) Notify the Contractor of their determination, and

(4) Modify the contract, as applicable, to reflect the determination. Contract items that need to be removed from the contract as a result of rejection or an inability to reach agreement are to be removed in accordance with 552.238-79, Cancellation.

(g) Effective date. EPA requests approved by the FSS Contracting Officer under this clause shall apply to orders issued on or after the effective date of the contract modification. Blanket Purchase Agreements (BPAs) may be modified by the ordering agency in accordance with the terms and conditions of the BPA.

(h) Update of contract pricing and catalog data. The Contractor shall update its FSS pricing and any other FSS catalog data in accordance with the terms and conditions of this contract.