GSA MAS Schedule Refresh 32 has been released and is now a practical contract-management matter for GSA Schedule holders. Our Coley GCS team has reviewed the changes for Refresh 32 and provides a discussion below of each change, why it matters, and recommended actions from an ongoing business, compliance, and opportunity-pursuit perspective.

For our clients, our team of GSA Schedule Advisors 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 Schedule contracts. If GSA SRefresh 32 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. Schedule a conversation with Coley GCS to review your GSA MAS Contract and keep your Schedule positioned for compliance, visibility, and growth.

Program-Wide Clause and Compliance Updates

Change: GSA has incorporated clause and provision updates, including implementation of Executive Order 14398 related to discriminatory DEI practices and additional updates through FAC 2026-01.

Why it Matters: This may create new compliance considerations for Schedule performance, subcontractor relationships, and agency reviews. GSA has indicated that these requirements may apply to subcontractors and lower-tier subcontractors, and that issues may be handled case by case.

Recommended Actions: Review the clause language and identify any contract-level implications. GSA Schedule holders should be review their company policies, subcontractor practices, teaming relationships, or agency inquiries connected to these requirements to ensure compliance.

Drone and Unmanned Aircraft Systems Requirements

Change: GSA has updated language for drones and unmanned aircraft systems. GSA’s draft language indicates that drones/UAS may only be awarded under MAS if they are included on the DCMA Special Programs US-X Blue UAS Cleared List.

Why it Matters: This affects contractors that sell drones, unmanned systems, related products, or integrated solutions that include UAS equipment. Nonconforming products may not be eligible for Schedule sale.

Recommended Actions: Companies should review any impacted contract offerings where applicable and be ready to confirm specific models, manufacturers, approved-list status, and whether any products should be removed, replaced, or repositioned.

End-of-Support Requirements for ICT Products

Change: GSA has added new requirements addressing End-of-Support dates and the availability of security updates for Information and Communications Technology products. This includes hardware, firmware, and software versions that no longer receive timely manufacturer-supported updates, patches, fixes, or security updates.

Why it Matters: This is one of the most important compliance changes for product contractors, especially IT and technology resellers. If a product is obsolete, nearing End-of-Support, or no longer receiving security updates, GSA may request additional information and may require removal, replacement, mitigation, or other corrective action.

Recommended Actions: Companies should begin gathering manufacturer support dates, security update availability, supply status, and replacement recommendations for ICT products currently awarded on GSA Schedule. Companies should then identify impacted awarded products and take action on contract updates required.

FAS Catalog Platform Product File Updates

Change: GSA has removed the National Stock Number column from the FAS Catalog Platform Product File. NSNs should only be listed in the Manufacturer Part Number field by authorized AbilityOne resellers when the item is on the Procurement List.

Why it Matters: This affects catalog accuracy and product file compliance for Schedule product contractors. Improper NSN usage may create upload issues or catalog compliance concerns.

Recommended Actions: Companies  will need to manage applicable FCP file updates if any awarded products are AbilityOne items or if NSNs are currently being used in product data for customer-facing identification.

Retirement of SIN 311423 Non-Perishable Foods

Change: GSA is retiring SIN 311423 for Non-Perishable Foods under the Facilities Large Category.

Why it Matters: Contractors holding this SIN may lose a Schedule pathway for these offerings. This could affect future sales strategy for non-perishable food products through MAS.

Recommended Actions: Companies should identify whether their GSA Schedule contract is impacted. If affected, companies should consider alternative sales channels, item removal, or any appropriate Schedule repositioning strategy.

SIN 532310 Rental and Leasing of Hardware Store Products

Change: GSA has updated the description and instructions for SIN 532310. The new language focuses on category class pricing, fixed rental rates, product tracking, invoicing controls, prohibited charges, and TAA compliance.

Why it Matters: Contractors using this SIN may need stronger controls around how rental products are priced, tracked, substituted, and invoiced. Variable pricing within the same category class will not be allowed, and certain charges, such as re-rental fees and environmental service charges, are identified as prohibited.

Recommended Actions: Companies should review impacted contract files and pricing structures. Companies using this SIN should be prepared to confirm rental categories, fixed pricing logic, inventory tracking capabilities, invoicing practices, TAA status, and any separate fees currently used in the commercial rental process.

New SIN 518210GM — Grants QSMO Marketplace

Change: GSA established a new IT SIN for the Grants Quality Service Management Office Marketplace. This SIN is intended to support federal grants management solutions and services, including software, cloud solutions, technology operations, business analytics, risk tools, subrecipient monitoring, grants performance management, and related services.

Why it Matters: This may create a new business development opportunity for existing MAS contractors that support grants management, IT modernization, SaaS, cloud, cybersecurity, financial systems, program management, or federal mission support.

Recommended Actions: Coley GCS can help evaluate whether this SIN fits a company’s current capabilities and awarded offerings. Companies interested in this opportunity should begin identifying relevant past performance, technical capabilities, software or service offerings, differentiators, and any demonstration-ready solutions.

SIN 54151HEAL Health Information Technology Services

Change: GSA revised the description for SIN 54151HEAL to clarify and expand the Health IT services covered, including connected health, EHRs, health information exchanges, health analytics, telemedicine, health informatics, modernization of legacy Health IT systems, and related services.

Why it Matters: This may improve positioning for contractors pursuing Health IT opportunities through MAS, but it also reinforces the need for awarded offerings and marketing language to align with the SIN scope.

Recommended Actions: Companies should review their awarded descriptions, as needed. Companies pursuing Health IT work should validate before positioning new capabilities under this SIN, especially if the work overlaps with broader IT, research, analytics, or healthcare operations support.

SIN 812910 Working Canines and Related Services

Change: GSA will revise the description and instructions for SIN 812910 to clarify that the SIN covers working canines and related products and services for official government mission requirements. The revised language excludes pets, companion animals, and emotional support animals. It also states that working canines should not be listed on GSA Advantage! and must use the Services Plus File option in FCP.

Why it Matters: Contractors under this SIN must ensure their offerings are positioned as mission-related working canine products and services, not general animal services or pet-related offerings.

Recommended Actions: Companies should determine if applicable catalog and file structure updates are needed. Clients under this SIN should confirm that service descriptions, certifications, equipment, training, and customer-facing materials align with official government mission requirements.

SIN 334290L Physical Access Control Systems

Change: GSA plans to remove “Legacy SIN” from the title of SIN 334290L Physical Access Control Systems.

Why it Matters: This appears to be a title cleanup rather than a substantive business change. It may reduce confusion in customer-facing references.

Recommended Actions: Companies should update contract materials, including capability statements, website language, and sales materials to match the revised title.

SIN 541620 Environmental Consulting Services

Change: GSA will add a note clarifying that services under SIN 541620 cannot include architect-engineer services as defined in the Brooks Act and FAR Part 2, or construction services as defined in FAR Parts 2 and 36.

Why it Matters: This is important for bid/no-bid decisions and scope compliance. Environmental consulting work may be appropriate under this SIN, but A-E services and construction work must be kept separate.

Recommended Actions: Companies pursuing environmental opportunities should coordinate early if a requirement includes design, engineering, remediation, construction, or construction-adjacent work so the proper contracting paths can be assessed.

Overall Takeaway

For most existing GSA Schedule holders, Refresh 32 is not expected to require broad action. The biggest practical impacts are likely to involve product lifecycle compliance, ICT End-of-Support management, SIN-specific catalog alignment, subcontractor-related compliance awareness, and business development opportunities under the new Grants QSMO SIN.

You may also be interested in Coley GCS posts on GSA Mass Mod A909 and mandatory TDR, the new DEI executive order, FCP transition guidance, and prior MAS refresh updates.