Top Four Ways to Avoid MAS Modification Rejections in 2023

In 2020, I outlined the Top Four Ways to Avoid MAS Modification Rejections. Because that blog was released when the General Services Administration (GSA) Multiple Award Schedule (MAS) Solicitation requirements included Digital Certificates rather than Federal Acquisition Service (FAS) IDs, and Data Universal Numbering System (DUNS) instead of Unique Entity Identifiers (UEIs), I'm revisiting what MAS contractors must do to avoid a Modification rejection three (3) years later in 2023.

1. Follow All Modification Instructions Exactly

Before you start the process, make sure you’re referencing the most current MAS Modifications Guide. Since the consolidation of the legacy Schedules in 2019, GSA has utilized one (1) master guide. However, there have been a few versions to accommodate MAS Program updates since 2020. I recommend that all contractors follow the solicitation on SAM.gov vigilantly for updates. Once a new Refresh has dropped, It’s important to grab the newest guide from GSA’s Modifications and Mass Modification Guidance page. Here you will also find sample cover letters for Modifications like Change of Name Agreement, Novation Agreement, Legal Certification of Name Change, etc., the Services and Training Price Proposal Template (PPT), and the Products PPT. While these templates won’t always change, Refresh #15 brought updates to the solicitation to accommodate a missing High School Equivalency option for proposed Labor Categories (LCATs).

There are still eight (8) MAS Modifications available for contractors to utilize: Administrative, Additions, Deletions, Pricing, Technical, Terms and Conditions, Change of Name and Novation, and Cancellation- each containing its own specific subgroups and instructions. However, keep in mind that GSA has, on occasion, announced a change in a Modification requirement through their MAS Interact Community page. Recently, GSA announced the following:

• Updating an Industrial Funding Fee (IFF) Point-of-Contact (POC) no longer requires an Administrative Modification. According to a notice on Interact, it’s now handled by requesting an update through your assigned Administrative Contracting Officer (ACO).

Because Interact is a forum for updates in real time, I advise all vendors sign up for emails from the MAS Interact Community to stay up to date.

Additionally, as you reference the guide, make sure to check out GSA’s recent Modifications Best Practices and Frequently Asked Questions (FAQs) for more insight.

2. Avoid Common Modification Pitfalls

According to GSA’s Modification Guide, these are the most common reasons a Modification is rejected:

• “Items to be added are out of scope for the proposed/awarded Special Item Number (SIN);
• Duplicate items or part numbers on spreadsheet;
• Adding items already on contract;
• Essentially the same (ETS) products as AbilityOne items being added;
• Math is incorrect on PPT;
• Pricing or discounts are incorrect;
• Attempt to delete items that are not on contract;
• Overhead is not included in the cost and is being charged separately;
• Using non-standardized part numbers;
• Proper type of Modification is not chosen in GSA eMod system;
• Incorrect documentation submitted with Modification;
• Irrelevant documentation submitted with Modification;
• All the required documentation is not initially submitted with Modification request; and
• Slow contractor response to Contracting Officer’s (CO) / Contracting Specialist’s (CS) comments or requests.”

These haven’t changed from 2020.

Bottom line, know exactly what you’ve been awarded, be vigilant that you’re accurately submitting information in the most recent templates, use the guide’s checklist before submitting, and respond ASAP to your CO’s requests.

3. Establish a Working Relationship with Your CO

As the CO reviews your Modification submission, they may reach out with requests for more information. Responding promptly to these requests will best facilitate the process and increase your chances for award. It’s important to note that all COs are different, a preference by one CO, such as touching base on the phone vs email, may not work for another. Also, some COs prefer to review Modifications via email prior to submission in eOffer. Make sure to inquire as to the process and cadence your CO prefers. Meet them where they’re at.

On occasions, I’ve seen COs who work so well with the contractor that, instead of rejecting the Modification outright, they will give them a chance to mitigate errors. If the contractor is both mindful of the CO’s time and works diligently to provide all the required information, the process will go smoothly for both parties.

4. Have an Up-to-Date SAM Record

There are Modification types that will require a copy of your SAM Record. Make sure all the information on your record is correct and that you’re renewing before the yearly expiration date. For contractors who hired an outside service to manage their entity record, be mindful that GSA is now restricting the role of Entity Administrator to only employees, officers, or board members of an organization. If you used an outside service to manage your record, GSA asks you to:

• “Send an Entity Administrator Appointment Letter to the Federal Service Desk (FSD) appointing an administrator, or
• Ask your outside Entity Administrator to assign the role to someone in your entity before March 3, 2023.”

Additionally, GSA knows that the transition from DUNS to UEI has caused a myriad of problems for contractors on SAM.gov. To mitigate this, they’ve recently provided the option for contractors to escalate their time-sensitive tickets to the MAS Project Management Office (PMO). If you’re struggling to update your record in time for a procurement opportunity, please email [email protected] with the following information:

• “An active entity validation ticket from FSD.gov.
• Entity Legal Business Name
• Entity UEI (optional, if available)
• Description of urgency (pending/past-due payment, pending award, pending bid, grant funds withheld, etc.)
• Brief description of assistance needed, or problem experienced.”

If your Modification is rejected once, it’s not game over. You will have the opportunity to re-submit. However, Modifications take time from submission to award and rejections only elongate the process. It’s important you’re doing everything you can to simplify the review process for the CO to not only save time but guarantee that all your desired services and/or products are on Schedule for customer agencies to procure.