
"The changes to transaction data reporting, or TDR, will apply to all MAS special item numbers by adding 112 SINs that were previously exempt. GSA will require contractors to report detailed sales transaction data to GSA on a quarterly basis. Once finalized, current MAS contract holders will receive a mass modification for the TDR requirement and must accept the change within 90 days."
"Part of the TDR change includes an end to the Price Reductions Clause, which requires contractors to notify GSA if they offered a better price for a product or service to a customer. This means that contractors will no longer have to track commercial price changes. GSA is also looking to reduce exposure to retroactive price reductions or payment demands, which have been the basis for False Claims Act lawsuits."
"The new AI provisions will standardize terms and conditions government-wide for the first time. GSA is incorporating provisions from the Office of Management and Budget's M-25-22 memo from April 2025, Driving Efficient Acquisition of Artificial Intelligence in Government. OMB's memo requires agencies to include contract terms that require vendors to get permission before using non-public government data to train their publicly-available AI algorithms."
The General Services Administration released Refresh 31, a draft of significant changes to the Multiple Award Schedule program affecting how federal agencies acquire commercial products and services. Key modifications include making transactional data reporting mandatory for all MAS special item numbers by adding 112 previously exempt SINs, requiring quarterly detailed sales data submissions. The Price Reductions Clause is eliminated, removing contractor obligations to track and report commercial price changes to GSA, thereby reducing False Claims Act litigation exposure. New standardized AI provisions incorporate OMB's M-25-22 memo requirements, mandating vendors obtain permission before using non-public government data to train publicly-available AI algorithms, ensuring government data ownership and control. Current MAS contract holders must accept modifications within 90 days for TDR requirements and 60 days for other Refresh 31 changes. GSA seeks public comments by March 20.
#gsa-multiple-award-schedule #transactional-data-reporting #artificial-intelligence-procurement #government-contracting #price-reductions-clause
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