On October 17, 2025, the General Services Administration (“GSA”) announced that it plans to issue a Mass Modification to GSA’s Multiple Award Schedule (“MAS” or “Schedule”) Solicitation[1] and Schedule contracts in November 2025 (“Refresh”).  Periodically, GSA may issue a Mass Modification to Schedule contracts to uniformly impose changes to the contract terms applicable to all Schedule contract holders, often as a result of changes in applicable law, regulation, or policy.  This approach also ensures that existing Schedule contracts have consistent terms, even though with the evergreen nature of the Solicitation those contracts have been entered into at different times and are at different stages of performance.

This Refresh (i.e., Refresh #30) will implement several significant changes with the goal to align the GSA Schedule with recent developments in the Revolutionary FAR Overhaul (“RFO”).[2]  Although the full text of the Refresh is not yet available, GSA’s Refresh outline provides insight into the changes that are to come as GSA seeks to gain implementation experience with the RFO clauses, provisions, and ordering procedures through its Schedule contracts.  Given GSA’s leadership of the RFO process, and this year’s Executive Order to consolidate domestic procurement of common goods and services in GSA to the extent permitted by law,[3] it is no surprise that it has acted quickly to revise its long-term government-wide contracting vehicle according to these recent developments. 

Along with the Refresh announcement, GSA opened a 10 business day comment window on buy.gsa.gov, which we expect will close on October 31, 2025.  Schedules contractors will be expected to accept the Refresh no later than 90 days from its release which is expected sometime in November.  Below we discuss relevant background on the RFO process as it relates to the Schedule and anticipated changes to provisions and clauses in the Refresh.  We will continue to watch for updates as GSA’s implementation of the RFO unfolds.    

Background:  RFO Implementation Status

• Part Changes Specific to the Schedule:  The RFO has proposed deleting FAR Part 38, Federal Supply Schedule Contracting, and Part 51, Use of Government Sources by Contractors, and consolidating regulations relevant to the Schedule in RFO Part 8, Required Sources of Supplies and Services.  Additionally, the RFO has proposed moving FSS ordering procedures from FAR Subpart 8.4 to RFO GSAR Subpart 538.71—Federal Supply Schedule Ordering Procedures. GSA has implemented these changes with class deviations for each RFO Part and the FSS Ordering Procedures.[4]
• General RFO Progress Updates:  As of September 30, 2025, model deviation text for all 53 Parts of the FAR has been released.  Although the majority of the model deviations are scheduled to become effective on November 3, 2025, the model deviation provisions must be adopted by agencies on a part-by-part basis: the status of agency adoption of each part is viewable at https://www.acquisition.gov/far-overhaul/far-part-deviation-guide.  Notice-and-comment rulemaking is expected to begin sometime late in 2025 to begin the process to codify the RFO version of the FAR.  GSA is relying on its deviation authority to implement the RFO versions of the FAR and GSAR in advance of the forthcoming notice-and-comment rulemaking.       

Updating Incorporated FAR Clauses and Provisions to Align with RFO Deviations

According to GSA’s “MAS Refresh 30 Clause and Provision Changes,” “Refresh 30 incorporates GSA deviations that align with” the RFO’s “revised regulatory framework,” particularly revisions that “simplify acquisition requirements, remove non-statutory provisions, and promote the use of plain-language clauses and provisions.”  As a result, GSA is (1) deleting clauses that, although still codified in the FAR, are proposed for removal under the RFO (2) adding new RFO clauses, and (3) replacing codified FAR versions with RFO deviation versions.  Although the MAS Refresh does not provide the text of the RFO clauses with this announcement of the Refresh, the RFO Part 52 provides the text we can likely expect to be included.  Some observations of the proposed clause changes are below:

First, GSA will delete 36 FAR clauses and provisions from the Schedule.  Notable deletions include: 

• Consistent with RFO Part 40, a variety of individual prohibition clauses have been incorporated into consolidated new RFO clauses in RFO 52.240-90 and 91, and therefore, the individual clauses will be deleted:
  • 52.204-23, Prohibition on Contracting for Hardware, Software, and Services Developed or Provided By Kaspersky Lab and Other Covered Entities (DEC 2023)
  • 52.204-24, Representation Regarding Certain Telecommunications and Video Surveillance Services or Equipment (NOV 2021)
  • 52.204-25, Prohibition On Contracting for Certain Telecommunications and Video Surveillance Services or Equipment (NOV 2021)
  • 52.204-30, Federal Acquisition Supply Chain Security Act Orders—Prohibition (DEC 2023) (ALT I DEC 2023)
  • 52.225-13, Restrictions On Certain Foreign Purchases (FEB 2021)
  • 52.225-25, Prohibition on Contracting With Entities Engaging In Certain Activities or Transactions Relating to Iran Representations and Certifications (AUG 2018)
  • 52.240-1, Prohibition on Unmanned Aircraft Systems Manufactured or Assembled By American Security Drone Act- Covered Foreign Entities (NOV 2024)
• Legacy consolidated clauses for commercial products and services will be deleted consistent with RFO Part 12, as the substance of these provisions will be included through the incorporation of the individual clauses instead:
  • 52.212-3, Offeror Representations and Certifications – Commercial Products and Commercial Services (MAY 2024) (DEVIATION FEB 2025)
  • 52.212-5, Contract Terms and Conditions Required To Implement Statutes or Executive Orders – Commercial Products and Commercial Services (JAN 2025) (DEVIATION FEB 2025)
• Clauses implementing the Buy American Act: 52.225-1, 225-3 (and its alternates), 225-11, and 225-23 will be deleted, though it appears that Trade Agreements Act requirements will remain in the Schedule Solicitation.

Second, GSA will add five new RFO clauses or provisions to the Schedule Solicitation—these new clauses or provisions reflect substance that was moved or consolidated into a new location as a result of the RFO: 

• 52.208-10, Government Supply Sources;[5]
• 52.209-11, Representations By Corporations Regarding Delinquent Tax Liability or A Felony Conviction Under Any Federal Law;[6]
• 52.240-90, Security Prohibitions and Exclusions Representations and Certifications;
• 52.240-91, Security Prohibitions and Exclusions;[7] and
• 52.240-93, Basic Safeguarding of Covered Contractor Information Systems.[8]

Finally, GSA will replace 53 FAR clauses and provisions with RFO deviation versions.  Depending on the type of products or services sold on the Schedule and the characteristics of the Schedule contractor entity, the deviation versions may have varying effect (including no meaningful impact) on the Schedule contractor.  Notably, GSA continues to issue reminders that the System for Award Management (“SAM”) is likely to lag behind “policy updates” under the RFO, with updates to SAM.gov projected for January 2026 at the earliest.  This means that entities are likely to continue to be required to complete representations in SAM that are not included in the Schedule Solicitation.  Although the Refresh notice states that contracting officers will rely on representations corresponding to the Solicitation provisions, entities are not able to remove inapplicable representations in SAM.

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[1] Refresh #30 to Solicitation No. 47QSMD20R0001.  The current MAS Solicitation (i.e., MAS Refresh #29) is available here or here.

[2] For more background on the current Administration’s effort to remake federal procurement, and progress in the Revolutionary FAR Overhaul, see our prior posts here and here.

[3] E.O. 14240, Eliminating Waste and Saving Taxpayer Dollars by Consolidating Procurement, 90 Fed. Reg. 13671 (Mar. 25, 2025).

[4] Agency-specific class deviations are available on the RFO website, posted under each respective part: https://www.acquisition.gov/far-overhaul/far-part-deviation-guide. 

[5] Note that this clause exists in the codified FAR at 52.251-1, Government Supply Sources, without substantive differences between the codified and RFO clauses.

[6] FAR 52.209-11 does not appear in the existing Schedule Solicitation, though the implementing clause at FAR 9.104-7(d) requires it in all solicitations.  The clause is being added as the RFO version of 52.209-11.

[7] The individual prohibitions listed above in the deleted clause/provision section have been consolidated into RFO 52.240-90 and 91.

[8] RFO 52.240-93 is the new location for FAR 52.204-21.