GSA’s Big Changes in 2020, Part 5: The Mass Mod Is Coming, the Mass Mod Is Coming . . . Wait, It’s Here!

Merle M. DeLancey Jr.

This is the last in a series of posts updating current and prospective Federal Supply Schedule (“FSS”) contractors about the big changes implemented or being implemented by the General Services Administration (“GSA”) in 2020—including consolidation of 24 schedules into one, streamlined schedule (called the Multiple Award Schedule or “MAS”). This post concerns GSA’s recent release of the Mass Modification (“Mass Mod”) implementing the terms and conditions for the MAS. Here is what you need to know:

      • If you have not received an e-mail with the Mass Mod, do not panic. The Mass Mod is being released on a legacy schedule basis. Some schedule holders will not receive the Mass Mod until February 11. Likewise, contractors with pending modifications to add or delete Special Item Numbers (“SINs”) will not receive the Mass Mod until those modifications are completed.
      • Contractors must accept the Mass Mod by July 31, 2020. It is mandatory. Failure to do so will result in your offerings no longer being accessible on GSA Advantage or the GSA eLibrary.
      • Contractors do not accept the Mass Mod in its entirety. Rather, contactors are asked to accept or request an exception to each clause in the Mass Mod. For each requested exception, a contractor must provide a justification. Ultimately, contractors will be required to negotiate all exceptions with their contracting officer.
      • If a contractor has not resolved all of its exceptions with its contracting officer by July 31, the contractor will not have accepted the Mass Mod (see above). GSA recommends that contractors reach out to their contracting officers before April 1 to ensure there is adequate time to negotiate exceptions before the July 31 deadline.
      • Contractors are not required to take exception to clauses that do not apply. As an example, GSA has routinely referred to Transactional Data Reporting (“TDR”). If you are not participating in the TDR pilot, you do not need to take exception to the TDR clauses.
      • Your assigned contracting officer, contract number, period of performance, prices, and products and services offered will not change as a result of acceptance of the Mass Mod. You are not required to re-represent your business size when accepting the Mass Mod. Participation in voluntary programs will carry over and not change. For example, if you participate in TDR, that participation will remain. If you are eligible and participate in Cooperative and Disaster Purchasing, it will automatically transfer to the new SIN structure.
      • A contractor’s existing SINs will be mapped and automatically migrated to the MAS’s new SIN structure and will show up on GSA eLibrary the day after a contractor accepts the Mass Mod.
      • Nine legacy SINs have been split into multiple new SINs. A contractor should be awarded all of the new SINs mapped to its legacy SINs. If a contractor believes its products and/or services have not been mapped to the correct new SIN, it can submit an add and delete SIN modification request after accepting the Mass Mod.
      • Acceptance of the Mass Mod will not automatically affect pricing or products loaded in GSA Advantage. After signing the Mass Mod, contractors will need to merge its SINs into GSA’s System Input Program (“SIP”). Within 30 days after accepting the Mass Mod, contractors will need to submit a revised catalog with its new MAS number and its products and/or services organized under its new SIN number(s). In addition, your price list should be revised to only include your new SINs.
      • If you have multiple legacy schedule contracts, you will receive multiple Mass Mods. You need to accept a Mass Mod for each of your current schedule contracts.

July 31 will be here before you know it. Contractors should not delay working on acceptance of the Mass Mod. It cannot be stressed enough that contractors should reach out to their contracting officers early and often with any questions and to negotiate any exceptions. Remember, contracting officers are responsible for multiple contractors. You need to take steps now to avoid what assuredly will be a melee during the last week of July.

Although this is our last post regarding GSA’s recent, big changes, including Schedules consolidation, as important developments occur, we will keep you informed.