govcon

GSA pushes out MAS refresh 24 by mass mod

GSA Schedule contractors are receiving notification to accept a mandatory mass mod to implement refresh 24 of the RFP.

Major changes include the following:

Prohibition on drones from foreign adversaries [52.240-1 (REFRESH #23)]: Implements the American Security Drone Act restrictions, prohibiting the use of unmanned aircraft systems (UAS) manufactured or assembled by covered foreign entities. This could significantly affect schedule holders supplying drone technology to the government.

Single-use plastic (SUP) packaging policies [552.238-118 (SUP Free Packaging Identification) (JUL 2024) and 552.238-119 (SUP Free Packaging Availability) (JUL 2024)]: Introduces requirements for identifying and making available SUP-free packaging options. This affects suppliers providing physical products and packaging solutions.

Removal of drug-free workplace clause [52.226-7 (REFRESH #21) (MAY 2024)]: Eliminates the requirement for contractors to maintain a drug-free workplace. While this simplifies compliance for some businesses, agencies may still impose similar requirements through other policies.

Updated notification of 8(a) competition: [replaced 52.219-18 (JAN 2017) (DEVIATED II - MAY 2024) with 552.219-18 (MAY 2024) (DEVIATION FAR 52.219-18)]: Updates the clause governing competition limited to eligible 8(a) participants, likely refining the processes for small business set-asides.

General updates to contract terms and conditions:

552.212-4: Contract Terms and Conditions - Commercial Products and Commercial Services (ALTERNATE I - NOV 2021) (JAN 2023)
552.212-4: Contract Terms and Conditions - Commercial Products and Commercial Services (JAN 2023)
52.212-5: Contract Terms and Conditions Required to Implement Statutes or Executive Orders (NOV 2024)
552.238-82: Modifications (Federal Supply Schedule) (JAN 2022): Reinforces the requirement for contractors to use eMod for submitting modifications, ensuring electronic updates for changes in pricing, item availability, and deletions.

These changes vary in impact, with technology and sustainability mandates having the most direct effect on compliance and eligibility for MAS contract holders. Have questions? Ask us.