Government Contracting: Does MAS Refresh End Contractor Ability to Buy from Schedule Contracts?

Written on January 13, 2020

One change made by the General Services Administration (GSA) in its recent update of the consolidated Multiple Award Schedule solicitation is causing confusion for both GSA and contractors. There is no need for panic. The ability for a government contractor to buy from a Schedule contract in support of the fulfillment of its own federal contract remains the same. While the refresh eliminated the FAR 51 deviation that had previously been used to place such orders, the FAR itself was previously updated to add FAR 51.03. This provision provides the same authority for contractors to place Schedule orders and makes it permanent so that no deviation is needed. Schedule contractors that accept orders from other contractors that want to buy from their contract must have a letter from an authorized government contracting officer allowing the buyer to make the purchase. Failure to obtain such a letter could have contract compliance ramifications for Schedule contractors. The order is treated just like any other Schedule order, is recorded as a Schedule buy, and the Industrial Funding Fee must be paid on it, just as with any other Schedule order. Here is a link to the permanent language.

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