GSA has updated its Multiple Award Schedule (MAS) ordering guidance to reflect post-Revolutionary FAR Overhaul (RFO) changes tied to Order-Level Materials, or OLMs. This update gives contractors and ordering activities clearer direction on how OLM pricing and sourcing can be handled at the order level.

GSA’s updated MAS guidance clarifies how Order-Level Materials (OLMs) may be priced and sourced under Schedule contracts, including when fair-and-reasonable determinations may occur and how contractors can use cross-contract sourcing under current MAS rules.

The update appears on GSA’s MAS Order Flexibilities page. It clarifies that fair-and-reasonable determinations for OLMs may be made at or after award in certain cases. It also confirms that contractors may source from other GSA Schedule contracts without separate authorization under the applicable GSAR deviation.

That may sound like a small procedural update. But for GSA Schedule contractors, it can affect how quotes are built, how pricing is supported, and how sourcing decisions are documented.

What Are Order-Level Materials (OLMs)?

OLMs are supplies or services acquired in direct support of an individual order placed against a MAS contract. They are not part of a contractor’s awarded Schedule offerings. Instead, they are added at the order level when needed to complete the work.

That might include supporting materials, specialized equipment, temporary labor, or other items tied directly to a specific order.

OLMs have always required careful attention because they sit outside the contractor’s standard Schedule pricing. That means contractors need to be clear about what is being included, why it is needed, and how the price is supported.

What Changed in GSA’s OLM Guidance?

One of the key updates is timing.

GSA’s updated guidance makes clear that fair-and-reasonable pricing determinations for OLMs do not always have to happen before award. In some cases, those determinations may be made at or after award.

This gives ordering activities more flexibility when managing MAS orders that include OLMs. It may also change how contractors prepare their pricing support, depending on the instructions in the order request.

That said, this is not a pass to skip documentation. Contractors still need to support their pricing and keep clear records. The flexibility is about when the determination may happen, not whether pricing still needs to be reasonable and supported.

GSA Clarifies Cross-Contract Sourcing for OLMs

The updated guidance also addresses sourcing from other MAS contracts.

GSA now makes it clear that contractors can source from other MAS contracts without obtaining separate authorization. This is an important clarification because some contractors have treated cross-contract sourcing as an area that required extra approval or added review.

For contractors, this may make it easier to build complete order-level solutions. It can help when a task order needs items or services that are available through another MAS contract and are needed to support performance.

But contractors should still be careful. Cross-contract sourcing must still follow the terms of the order, MAS requirements, and any applicable procurement rules. The update creates flexibility, but it does not remove the need for compliance.

Why MAS Contractors Should Review the Updated OLM Guidance

MAS contractors should review the updated OLM and cross-contract sourcing rules before submitting quotes or building order-level pricing.

Many companies have internal pricing and review procedures based on older assumptions. Those procedures may still work, but they should be checked against the updated guidance.

This is especially important for proposal teams, contracts teams, and pricing teams. Everyone involved in building MAS order responses should understand how OLMs are handled, what support may be needed, and how cross-contract sourcing can be used.

Contractors should also pay close attention to each order’s instructions. Some ordering activities may use the added flexibility right away. Others may continue using more traditional review methods. The best approach is to read the request carefully and provide clear pricing support either way.

Need help reviewing your GSA Schedule contract procedures or adjusting your OLM compliance approach? Coley’s GSA Schedule Contract Management & Compliance services help contractors stay aligned with current MAS guidance, contract requirements, and evolving acquisition policy changes.

Why Agencies May Apply OLM Guidance Differently

This update matters for agencies too. Ordering activities may start applying the OLM guidance in different ways depending on the order, the timing, and the type of support needed.

Some agencies may be more comfortable making fair-and-reasonable determinations after award when the guidance allows it. Others may still prefer to complete that review before award.

That means contractors should not assume every buyer will handle OLMs the same way. Clear communication and complete documentation are still the safest path.

More GSA Acquisition Policy Updates Are Likely

The Schedule program continues to change as GSA works through RFO-related updates and related acquisition policy changes. This OLM clarification is one more example of broader policy changes showing up in day-to-day Schedule ordering guidance.

Contractors should expect more updates over time, especially around order-level evaluations, pricing flexibility, commercial buying practices, and Schedule administration.

Staying current matters. A small change in guidance can affect how a quote is prepared, how a sourcing decision is documented, or how an agency reviews an order.

Final Thoughts on GSA’s OLM Guidance Update

GSA’s updated MAS ordering guidance gives contractors more clarity on OLM pricing determinations and cross-contract sourcing. It also gives ordering activities more flexibility in how certain order-level decisions are handled.

For GSA Schedule contractors, the main takeaway is simple: review your procedures before submitting quotes that include OLMs or cross-contract sourcing. Make sure your team understands the updated rules, keeps strong documentation, and does not rely on outdated assumptions.

A quick review now can help avoid confusion later and make future MAS order responses cleaner, faster, and easier to support.

Need Help Managing OLM Compliance and MAS Updates?

As GSA continues updating MAS guidance and acquisition policies, contractors need to ensure their pricing procedures, sourcing practices, and contract administration processes stay aligned with current requirements.

With over 25 years of experience, Coley GCS has helped thousands of companies successfully win and manage GSA MAS Schedules, GWACs, and IDIQ contracts. Our dedicated team of experts provides ongoing support to ensure your Schedule stays compliant, competitive, and positioned for long-term success in the federal marketplace. From initial acquisition to modifications and annual compliance, we make the process easy and efficient, so you can focus on growing your government business.

Need help maximizing return on investment? Coley GCS also provides Business Development support and training that has helped companies win over $26 Billion in new contracts.

Contact us at hello@coleygcs.com, call us at 210-402-6766, or book time with our team to speak with one of our contracting expert.