GSA MAS Refresh 31: Solicitation Updates March 2026:

• AI Policy is being postponed for a future refresh while industry comments on the new language until April 3rd: Read the clause here and send comments to maspmo@gsa.gov
• Refresh 31 will be released in April
• Expansion of Transactional Data Reporting (TDR) to include all remaining Service SINs and the establishment of TDR as a mandatory requirement for all SINs under the MAS Solicitation.
• GSA is implementing additional Transactional Data Reporting (TDR) data elements.
  • Ship Date – This data element is applicable only to MAS product transactions
  • Order Date – This data element is applicable to only MAS product transactions
  • Zip Code Shipped to – This data element is applicable to only MAS product transactions
  • Federal Customer – Treasury Agency Code. This data element is applicable to all offering types.
  • Cloud Service Type. This data element is only required to be reported for transactions under the Cloud SIN (518210C – Cloud Computing and Cloud Related IT Professional Services).
  • Unique Catalog Identifier (UCID). This data element will apply to any offerings that include a UCID in the awarded Price List / Catalog. The field is not applicable to Fixed Price service contract order types/contracts.
  • Order Type. This data element is applicable to all offering types.
  • Order Discount. This data element is applicable only in limited circumstances to Highly configurable (HCP), configurable services (CS), and the Cloud SIN.
  • Worksite. This data element is applicable for services transactions only under Time and Material and Labor Hour contract types. See worksite definitions in the FAS Catalog Platform (FCP) Services Plus File which is available on the FCP help page.
• Change to Service Data Requirements in TDR:
  • FAS requests additional information to be reported under the existing “Description of Deliverable” data element to provide greater detail about what is being acquired.
  • For Professional and SCA/SCLS firm fixed price service contract order types above $1 million, vendors must upload PWS/SOO/SOW one time upon initial task order award in the Sales Reporting Portal.
  • For Highly Configurable Products (HCP) where the contractor is awarded a manufacturer/family/series of products and awarded MAS pricing is a defined discount off of the vendor’s commercial pricing, and Configurable Services (CS) orders regardless of dollar value, vendors must upload invoice/Bill of Materials (BOM)/etc with a breakdown of products for each line reported.

GSA’s upcoming MAS Refresh 31 introduces targeted policy updates that affect how contractors manage pricing compliance, report sales data, and structure offerings under their Schedule contracts. Key changes include mandating Transactional Data Reporting (TDR) across all SINs, updated restrictions within the Startup Springboard program, and clarified expectations for the use of Order-Level Materials (OLMs) and Open Market items.

These updates do not require immediate action from most contractors, but they reinforce GSA’s continued focus on pricing transparency, Schedule-first purchasing, and long-term contract readiness. Our team is actively monitoring the refresh and will guide each client through any implications specific to their contract.

A Mass Modification (Mass Mod) will follow the refresh and must be accepted to keep contracts current and compliant.

Key Policy Updates to Watch on GSA Refresh 31

Transactional Data Reporting (TDR) Expansion to All SINs

Under MAS Refresh 31, TDR will be mandatory across all Special Item Numbers (SINs). Contractors under TDR agree to report transactional sales data at the order level in exchange for relief from Commercial Sales Practices (CSP) disclosures and ongoing Price Reductions Clause (PRC) tracking.

Note that all current non-TDR contractors will be automatically migrated to TDR under this mass modification. TDR can simplify certain pricing compliance requirements and lower contractor risk of non-compliance and false claim violations, but it also introduces new reporting responsibilities. TDR sales are reported monthly, rather than quarterly and as the name suggests, the report requires transactional information. If a contractor is selling products or billing Time & Material contracts, each line item will be delineated with product/category, price, quantity, etc. If you are billing firm-fixed price orders, then you can report as one line item. It’s important to review your accounting systems’ capabilities and ensure compliant ease of reporting.

Contractors with offers in review at GSA that are were not submitted as TDR are being asked to withdraw their offer and resubmit as TDR eligible. Non-TDR offers not withdrawn will be rejected.

New GSA Springboard Restrictions

Refresh 31 introduces tighter guardrails around the Startup Springboard program The Startup Springboard is a pathway for newer firms with limited past performance (less than two years) to obtain a GSA schedule. The updated restrictions limit eligible vendors to those submitting under existing federal IT initiatives and that are able to obtain a letter from an agency requesting the vendors participation in the Springboard Program. Current IT initiatives include:

• Second Generation Information Technology IT BPAs awardees
• Defense Health Agency Enterprise IT Services
• SCRIPTS BPA – Supply Chain Risk Illumination Professional Tools
• Other IT initiatives that arise (such as contract modification initiatives)

This change is a major blow against new federal contractors providing non-IT services to the federal government. It appears all non-IT vendors will need a minimum of two years of corporate experience, sound financials, and relevant past performance (resumes may work for some). .

GSA Refresh 31 Changes to OLM/Open Market SINs

Following the guidance of the Revolutionary FAR Overhaul (RFO), GSA is opening the Order Level Materials (OLM) SIN to all vendors removing subcategory limitations. The RFO has also applied restrictions to Open Market Item, requiring them to meet the same structured approach as OLMs. This change essentially mandates OLM use over Open Market Item use on all MAS orders.

Why this matters for clients: Contractors that rely heavily on OLMs or Open Market items may face increased scrutiny during audits, modifications, or task order reviews. Startups and early-stage Schedule holders should expect greater emphasis on compliant processes. We actively monitor these thresholds and help clients reduce risk while preserving flexibility.

Coley GCS Handles all GSA Schedule Modifications

Our team of GSA consultants closely track every solicitation refresh, GSA Mass Modification, and policy update, so government contractors do not have to sort through refresh language or Mass Mods on their own. We focus on how those changes actually affect active GSA contracts. If MAS Refresh 31 impacts your GSA Schedule contract, we can identify the issue, explain what it means in clear, contractor focused terms, and manage the required actions for you. Even if you are not currently a Coley GCS client, our team is available to review your GSA Schedule, answer questions, and help you stay compliant as GSA requirements continue to shift.

Since 2001, Coley has helped thousands of companies obtain and successfully manage government contracts. Contact us today at hello@coleygsa.com or 210-402-6676, or book a consultation to get started. If you’re a government contractor looking for business development resources and exploring ways to grow in the federal market, check out FedMap.us — the #1 growth-focused online community for government contractors.