GovCon Shake-Up: Key Changes in GSA MAS Refresh 29 and FAR 2.0 You Can’t Afford to Ignore
Introduction
As we move toward Fiscal Year 2026, the government contracting environment is undergoing a strategic transformation, shaped by a new administration and a clear consolidation of procurement power. Central to this evolution is the GSA Multiple Award Schedule (MAS), which has seen its sales surge from just under $40 million in FY21 to over $50 million in FY24, underscoring its increasing dominance. The GSA MAS, along with GSA Oasis Plus and the upcoming SUP 6, are now designated as “best in class,” making them mandatory-use vehicles for many acquisitions and signaling a new era of centralized federal buying.
These are not piecemeal updates. Taken together, the changes in GSA MAS Refresh 29 and the FAR 2.0 rewrite signal a clear GSA strategy: to professionalize the MAS vehicle, increase data-driven oversight, and concentrate federal spending through a smaller pool of high-performing contractors. This article distills the most surprising and impactful changes every contractor must understand to stay competitive.
The “Rule of 2” Isn’t What You Think on Task Orders
The FAR 2.0 rewrite has introduced a significant clarification to FAR Part 19 that will reshape small business strategy. The new rule explicitly states that the “Rule of 2”—the requirement to set aside an acquisition for small businesses if two or more are expected to bid—does not apply to task orders issued under multiple award contracts. While this may initially seem like a setback, the strategic implication is one of speed and efficiency. This change gives the government greater flexibility and, by streamlining the task order award process, may ultimately play in favor of agile small businesses who are prepared to compete directly and win.
Transactional Data Reporting is No Longer Optional
With Refresh 29, GSA has officially ended the voluntary Transactional Data Reporting (TDR) program, making it mandatory for all MAS schedule holders. The impact is direct: contractors will now be required to report their invoice data at the line-item level every month. GSA’s motivation is to gather comprehensive data to justify its central role in federal procurement and streamline reporting to the executive branch and Congress. This shift demands that contractors not only have robust accounting systems but also a strategy for how their pricing data will be perceived in a newly transparent market.
The Joint Venture Clock Starts Ticking Immediately
Joint Ventures (JVs) can hold their own MAS schedule and leverage the past performance of their member companies, but Refresh 29 highlights a critical and easily missed rule. The moment a MAS schedule is awarded to a JV, a two-year clock begins, limiting the JV’s eligibility to be awarded any other new prime contracts. While the MAS schedule itself can last for its full term, this limitation requires careful strategic timing. The decision to secure a MAS schedule for a JV must now be weighed against the partnership’s broader pipeline. Furthermore, a single company is limited to participating in a maximum of three JVs with MAS schedules, demanding a deliberate choice of partners and opportunities.
There’s a New Pressure to Perform: Meet Sales Targets or Face a “Timeout”
GSA is actively managing the size of its schedule program—effectively “culling the herd”—by off-ramping vendors who fail to meet minimum sales targets. The thresholds are specific: contractors must achieve $100,000 in sales during the first five-year base period and $125,000 during the subsequent five-year option period. The consequences for failure are severe. GSA will cancel the schedule and place the vendor in a “timeout” for up to 24 months, prohibiting them from reapplying. This policy marks a fundamental shift from a “get and hold” mentality to a “win or lose” imperative, forcing all schedule holders to prioritize active and consistent business development.
A Higher Ceiling for Simplified Buys
In a significant positive development for contractors, the FAR 2.0 rewrite expands the Simplified Acquisition Procedures (SAP) under FAR Part 12. The threshold has been raised to $7.5 million, allowing agencies to make larger purchases through the MAS schedule with significantly less friction. This change is a major tailwind for contractors, as it is designed to increase both the volume and value of opportunities flowing through the schedule. For companies positioned to deliver, this higher ceiling represents a direct path to larger, more streamlined awards.
Your Next Move—From Passive Holder to Active Winner
The mandatory reporting, stricter sales targets, and nuanced JV rules are not isolated changes; they are a clear directive from GSA. Survival and growth in this new environment depend on shifting from passive schedule holding to active, strategic management. This requires immediate action in three critical areas:
Re-evaluate Compliance: Take a fresh look at your schedule management. If you lack dedicated in-house expertise, consider engaging a third-party firm to ensure you maintain compliance with all new requirements.
Expand Your Portfolio: Use this as an opportunity to review and strategically expand your list of labor categories and Special Item Numbers (SINs) to position your company for the widest possible range of opportunities.
Master the Task Order Process: Build a repeatable business process specifically designed to qualify, bid on, and win task orders. This is no longer an ancillary activity; it is the core engine for growth on the MAS schedule.
If you’re not actively engaged, you’re making a no-bid-by-default decision, and that doesn’t contribute to your growth.