The Order-Level Materials (OLM) Special Item Number (SIN) under the GSA Multiple Award Schedule (MAS) Contract (also known as the GSA Schedule) is a unique SIN. It was first introduced in 2018 and underwent significant updates in 2026, which are intended to minimize the need for open market items.
- What is the Order-Level Materials SIN?
- What is the Purpose of the OLM SIN?
- How Has the OLM SIN Changed in 2026?
- How is the GSA OLM SIN Different from Ancillary or ODC SINs?
- How is the GSA OLM SIN Different from Open Market Items?
- OLM vs Ancillary vs Open Market Comparison Chart
- Special Procedures for the OLM SIN
- Who is Eligible to Obtain the Order-Level Materials SIN?
- Order-Level Materials Summary
What is the Order-Level Materials SIN?
The OLM SIN allows companies to offer supplies and services through their GSA MAS Contract at the order level that:
- Are unknown or can’t be priced at award of their GSA MAS Contract, and
- Are incidental, not the primary purpose of the order, and
- Directly support the main objective of the GSA MAS Contract order
The OLM SIN was first introduced in June of 2018 to select GSA Schedule categories. Since then, it has been expanded. As of Refresh 31, all GSA MAS Contractors have a one-time opportunity to accept the mass modification that adds the OLM SIN to their GSA MAS Contract. Please note, OLM is not applicable to VA Schedule Contracts.
What is the Purpose of the OLM SIN?
The GSA Schedule Contract vehicle offers buyers several benefits, including simplified ordering process, pre-negotiated pricing, and reduced administration. However, the GSA Schedule lacked some flexibility that other indefinite delivery, indefinite quantity (IDIQ) contracts allowed for.
Prior to the OLM SIN, companies could not include supporting products/services on the GSA Schedule that were defined and priced at the order level. Depending on the type of offering, this inability prevented some companies from providing a total solution through their GSA Schedule, which potentially pushed buyers towards other contract vehicles.
The GSA OLM SIN is Intended to:
- Help the GSA Schedule better compete with other ID/IQs.
- Increase government purchases through the GSA Schedule.
- Ultimately contribute to a reduction in contract duplication.
How Has the OLM SIN Changed in 2026?
The year 2026 brought significant updates to how Order-Level Materials work under the GSA Schedule. Driven by the FAR Overhaul, MAS Refresh 30 and Refresh 31 rolled out changes to minimize the need for open market items and expand the flexibility of the OLM SIN for both buyers and sellers. If you’re already familiar with OLMs, here’s what you need to know:
| What Changed | Details |
| Universal Eligibility | The OLM SIN was previously limited to contractors holding a SIN under specific OLM-eligible subcategories. As of MAS Refresh 31 (April 2026), all GSA MAS Contractors are now eligible to hold the OLM SIN. |
| Fixed-Price Orders Now Allowed | OLMs were previously restricted to Time and Materials (T&M) or Labor-Hour (LH) CLINs. Under the new “Federal Supply Schedule Ordering Procedures“, OLMs can be used to support any authorized order type, including fixed-price orders. |
| “Open Market” Renamed to “Non-MAS” | The FAR Overhaul rebranded open market items as Non-MAS items. These must now be clearly labeled as “Non-MAS” rather than “open market” on any GSA MAS Contract order. |
| Updated Procedure Citation | The governing procedure for OLMs has moved from GSAR 552.238-82 to GSAR 538.7104-2 (GSA Class Deviation RFO-2025-FSS-GSAR 538). |
| 33.33% Limitation Removed | The previous 33.33% cap on OLMs no longer applies under the new FSS ordering procedures. OLMs still must not be the primary purpose of the order, but there is no strict dollar-value threshold. |
| OLMs Must Be Commercial Items | OLMs must now explicitly satisfy the definition of a “commercial product” or “commercial service” under FAR 2.101. The OCO is responsible for verifying this at the order level. |
| Supply Chain & Compliance Requirements | All OLMs must adhere to FSS contract terms and conditions, including TAA compliance, cybersecurity supply chain risk management (CSCRM), and applicable security prohibitions. |
Bottom line: OLMs are now more accessible and more flexible than ever. All MAS contractors can add the OLM SIN, fixed-price orders are now in play, and the old 33.33% cap is gone. If you haven’t reviewed your GSA Schedule contract in light of these changes, now is the time.
How is the GSA OLM SIN Different from Ancillary or ODC SINs?
You may be wondering how the Order-Level Materials SIN differs from Ancillary SINs, which have historically been in place under the GSA Schedule. Like the OLM SIN, Ancillary SINs allow for supplies or services that are not covered under other SINs, but are ordered in conjunction with or in support of GSA Schedule orders and BPAs.
The difference between the OLM SIN and Ancillary SINs is that supplies and services under Ancillary SINs are known and can be priced when you receive your GSA MAS Contract award. Supplies and services under the OLM SIN are unknown at the time of your contract award, and cannot be priced.
How is the GSA OLM SIN Different from Open Market (Non-MAS) Items?
Open market items, now referred to as non-MAS items, are products/services that are quoted with a GSA Schedule order for the convenience of your buyer, but are NOT considered a GSA Schedule purchase. When you include an open market item with a GSA Schedule quote, you must clearly label it as “Non-MAS”. Open market items should not be reported with GSA Schedule Sales and should not factor into IFF payments.
Items quoted under the OLM SIN are considered a GSA Schedule purchase. Unlike open market items, contractors should include OLM sales in GSA Schedule sales reporting and should pay IFF.
If you have to pay IFF on OLM items, why wouldn’t you want to sell them as open market instead?
First of all, depending on how you negotiated your pricing, your buyer is technically paying the IFF and you are simply collecting and remitting it to GSA.
Secondly, quoting open market items could disqualify you from competing for some RFQ’s. We’ve seen RFQ’s where the Contracting Officer has specified that all items must be GSA Schedule items; open market items do not meet this requirement.
Finally, adding open market items to your order puts additional work back on your buyer, requiring them to complete extra steps. In addition to determining that the pricing of open market items is fair and reasonable (which is also required for OLM items), your buyer must follow all applicable acquisition regulations, including:
- Part 5 – Publicizing
- Part 6 – Competition Requirements
- Part 12 – Acquisition of Commercial Items
- Parts 13, 14, and 15 – Contracting Methods
- Part 19 – Small Business Programs
OLM vs Ancillary vs Open Market
Comparison Chart
- Firm Fixed Price (FFP)
- Time-and-Materials (T&M)
- Labor-Hour (LH) Contract Line Item Number (CLIN)
| Status at GSA Contract Award | GSA Schedule Item | IFF Applies | Priced At | Allowable CLIN Types |
|
| OLM | Unknown | Yes | Yes | Order Level | FFP/T&M/LH |
| Ancillary | Known | Yes | Yes | Schedule Level | FFP/T&M/LH |
| Open Market | Unknown | No | No | Order Level | All |
Special Procedures for the OLM SIN
If your company holds the OLM SIN, you’ll be required to meet some additional requirements when you quote for OLM products/services. Unless you have an approved purchasing system, you’ll have to collect at least three quotes for each OLM item over the Simplified Acquisition Threshold.
Who is Eligible to Obtain the Order-Level Materials SIN?
We should first note, the OLM SIN is not a standalone SIN. It may only be used in conjunction with another SIN. Prior to Refresh 31 in 2026, the OLM SIN was only available to companies that held a SIN under a GSA MAS Subcategory authorized for OLM. Today, all GSA MAS Contractors are eligible to hold the OLM SIN.
Order-Level Materials Summary:
- OLMs are supplies or services that cannot be defined or priced at the time of award, they are added at the order level.
- OLMs must be incidental and not the primary purpose of an order.
- OLMs must be in direct support of a task or delivery order placed against a GSA MAS Contract or Blanket Purchase Agreement (BPA).
- OLMs must be clearly identified in an order.
- IFF must be included in OLM price charged.
- OLMs should be included in GSA Contract sales reports and IFF remittance.
- There is no percentage limitation to OLMs (however, they must not be the primary purpose of the order).
- OLM pricing is evaluated by the Ordering Activity/Contracting Officer.
- As of MAS Refresh 31 (April 2026), all GSA MAS Contractors are eligible to hold the OLM SIN.
Use of the OLM SIN has picked up over the past few fiscal years to reach over $500 million in annual sales. Overall, the OLM SIN provides buyers and sellers greater flexibility under the GSA Schedule. A product or service that wouldn’t normally fit within the GSA Schedule can potentially be included under the OLM SIN, provided it’s used in support of a GSA order.
Need help keeping up with changes and updating your GSA Contract? Contact us!