MAS Contractors: Keep These Things in Mind for 2023

As a General Services Administration (GSA) Multiple Award Schedule (MAS) contractor, you were perhaps sold the idea of a direct link to the government contracting community. However, a MAS contract does not guarantee immediate success. You are solely responsible for your Schedule’s maintenance, compliance, and Business Development (BD) strategy. This year, as you plan your MAS success strategy, I’ve outlined some issues and pending initiatives all contractors should know.

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SAM.gov Issues Persist

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In Spring of 2022, the federal government transitioned from Data Universal Numbering System (DUNS) to Unique Entity Identifier (UEI) for federal award identification on all Integrated Award Environment (IAE) systems. GSA played a key role in this transition by assigning UEIs to active and inactive entity registrations, and ensuring the update across all systems. However, the transition has been anything but smooth, and in Fall of 2022, an estimated 50,000 companies and grantees were suffering delays in awards and payments as a result.

The Department of Defense (DoD) acted quickly to mitigate this issue for their contractors. In September of 2022, DoD released a class deviation where the contractor is required to be registered on the System for Award Management site (SAM.gov) within thirty (30) days post-award, as long as the contractor showed proof they at least started the registration process.

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On the MAS side, GSA alerted contractors of a mismatch between an entity's name in SAM.gov and MAS systems that triggered a Name Change, Address Change, or Novation Modification. This error is a result of the UEI transition, which, as our partners at PilieroMazza noted, resulted in SAM.gov not finding an entity’s correct legal name and/or full address (like suite number). GSA advised contractors to ignore emails with the subject line “Reminder to create a change of name, or novation modification” if you do not require these changes.

As of January 2023, UEI transition failures still persist. And while GSA has been working hard to resolve this issue, contractors should be mindful of their standing on SAM.gov.

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More MAS Refreshes to Come

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Contractors have seen many revisions (known as Refreshes) to the MAS Solicitation since the implementation of the Consolidated Schedule in 2019. In fact, 2020 saw five (5) solicitation refreshes, 2021 saw four (4), and 2022 saw five (5) in quick succession. While I can’t accurately estimate how many changes the solicitation will see in 2023, GSA has already kicked off the new year with Refresh #15 on January 18, 2023. And in the following ninety (90) days, MAS contractors are expected to accept the terms and conditions of the Refresh #15 Mass Modification.

As a reminder, each Refresh could bring changes to clauses, provisions, instructions, and/or MAS submission and Modification templates. I advise all MAS contractors, current and prospective, to follow the solicitation on SAM.gov and MAS Program Interact Community to track all updates in the near future.??

MAS Modifications Updates

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Modifications, or “Mods,” are a crucial component for contractors to update their offerings on Schedule. And there’s not a “one size fits all” for submission. Each Mod has its own unique instructions and requirements. Contractors are advised to adhere to the latest Mas Modification Guidance as they assemble their submission.

GSA also identified the following as “Best Practices” for modifying a Schedule:

• “Notify your Contracting Officer (CO) / Contract Specialist (CS) if you have a high priority modification or if it should be expedited to support a buyer. Note: expedited requests must provide evidence of a pending Task Order or closing RFQ and a request from the buyer.?
• Plan ahead! If you are aware of an upcoming business opportunity and need to modify your contract accordingly, don’t wait. Submit your modification request as early as possible to ensure it can be awarded on time.
• Ensure all the documents that are submitted with the modification are current to the most recent solicitation refresh and all required documents specific to the modification type are submitted.
• Use the MAS Modification Guide found on the Modifications and Mass Modification Guidance page. This page also has specific instructions for submitting EPA modification requests. Please note, COs are responsible for ensuring the modification request is justified and may ask for additional information, if necessary.
• For pricing modifications, if the new price is significantly higher than the current price on Schedule, providing an explanation with supporting documentation for the CO/CS may help speed up the review process.
• Consolidate modifications when possible to facilitate evaluation and shorten processing time.
• Submit multiple additions in one addition modification and multiple deletions in one deletion mod.?
• ?AbilityOne Authorized Distributors.?Add your new AbilityOne (AB1) products separately. Adding these, along with thousands of other commercial products, takes longer to process than if you submit AB1 products separately. Stay in compliance! Per Commission Procedure 51.540-01, all authorized distributors must make the appropriate additions and deletions to Federal contracts to reflect changes in the AbilityOne product offering within the effective date (normally 45 days after issuance) of the appropriate product list.”

As a MAS consultant, I’ve seen modifications take an average of two (2) to three (3) months to be awarded. So, make sure to compile and submit your mod in a timely fashion to complement your business needs.

Mod Updates to Note

GSA has taken action to reduce the administrative burden on contractors by expediting the process to update an Industrial Funding Fee (Fee) Point-of-Contact (POC). Now, instead of submitting an Administrative Modification, contractors can instead request an update through their Administrative Contracting Officer (ACO). If you need to make an update, but aren’t sure who your ACO is, simply use their ACO Locator tool on the Vendor Support Center homepage.

Catalog Management News

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On December 1, 2022, all MAS contractors were required to download version 9.0 of Schedule Input Program (SIP) in order to maintain access to digital catalogs. However, SIP’s reign is coming to an end in the next year. It’s time to become acquainted with its replacement: Common Catalog Platform (CCP).

As a reminder, in late 2021, GSA contracted CGI Federal to develop CCP, an Application Programming Interface (API)-accessible, web-based application to manage catalog data. CCP integrates with contracting systems like eMod and GSA Advantage! and introduces new functionalities that make it easier to manage catalogs.

The CCP Pilot is scheduled to release in March 2023, however, not every contractor will be impacted. For the pilot, only contractors awarded Office Supplies 4th Generation (OS4) Special Item Number (SIN) 339940OS4 who hold one (1) contract with no Blanket Purchase Agreements (BPAs) were selected to participate. When the pilot proves successful, GSA plans to transition ALL MAS contracts to CCP through a Mass Modification in early FY2024.

If you’re not a OS4 contractor, but currently use SIP to manage your digital catalog, keep these things in mind:

• ?In order to make changes to your catalog via CCP in the future, you must have a Federal Acquisition Service (FAS ID) and be an Authorized Negotiator. Recently, GSA confirmed that this rule also applies to contractor representatives.

• GSA will provide further instruction before CCP impacts all MAS contractors. Make sure you’re checking all MAS emails and following the MAS Program Interact Community Page.

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TDR for All SINs?

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Since the Transaction Data Reporting (TDR) pilot hit the scene in 2016, it has returned some favorable results. GSA reported from FY 19 to FY 21 this sales reporting option consistently reduced the burden on industry partners, generated stronger sales growth, and returned better contract-level pricing. In 2021, GSA announced their plan to expand TDR from their current list of eligible SINs to all SINs across Schedule the following year. However, that plan hasn’t come to fruition. In 2022, GSA did host an event entitled Vital Information Regarding the New Transactional Data Initiative, reviving hopes that the expansion would come soon. However, since then, all information regarding this event has been erased from the site and no further announcements have been made. I'm hoping to see this initiative come to life in 2023 and encourage you to track with us throughout 2023.

Wishing you and your MAS Schedule a successful 2023!