Significant Changes in GSA MAS Solicitation Refresh 27: Letter of Supply Requirements and TDR Expansion

The General Services Administration (GSA) has rolled out a major update to its Multiple Award Schedule (MAS) program with Solicitation Refresh 27, on June 26, 2025. This refresh introduces several pivotal changes that will impact both current and prospective GSA MAS contract holders. Among the most notable are the streamlined Letter of Supply (LOS) requirements and the expansion of the Transactional Data Reporting (TDR) program. This article provides a detailed overview of these changes, their implications, and what industry partners need to know.

Overview of GSA MAS Solicitation Refresh 27

GSA’s MAS program is a cornerstone of federal procurement, offering a simplified process for government agencies to purchase commercial products and services. Solicitation Refresh 27 represents a significant step in modernizing and refining the program, with changes designed to reduce administrative burdens, clarify requirements, and enhance transparency through expanded data reporting.

Key areas of change include:

• Revised Letter of Supply (LOS) requirements

• Mandatory Transactional Data Reporting (TDR) for additional SINs

• Retirement of select Special Item Numbers (SINs)

• Updated Service Contract Labor Standards (SCLS) wage determinations

• Clarifications and updates to pricing, product, and service offerings

Below, we delve into the most impactful changes, with a special focus on LOS and TDR.

Letter of Supply (LOS) Requirements: Streamlining for Industry

One of the most significant changes in Refresh 27 is the reduction and clarification of Letter of Supply (LOS) requirements. Previously, a LOS—a document from a manufacturer authorizing a reseller to distribute its products—was required for a broad range of MAS SINs. This created administrative hurdles for many contractors, especially those offering products outside of Information Technology (IT) and certain specialized equipment.

What’s Changing:

• LOS Now Required Only for IT and Printing/Photographic Equipment:
  Under Refresh 27, the LOS requirement is limited to the Information Technology Large Category (Category F) and the Printing and Photographic Equipment Subcategory (A10 under Category A: Office Management).

• Other Categories and SINs:
  For all other categories and subcategories, a formal LOS is no longer required. However, contractors must still be authorized by the manufacturer to distribute the products they offer, in accordance with the applicable contract clause, which states that contractors “shall not offer or sell products under this contract for which they do not have authorization, as applicable, and they lack an uninterrupted source of supply sufficient to satisfy the Government’s requirements.”

• Validation for Non-IT/Printing/Photo Products:

  • If the manufacturer participates in the Vendor Partner Program (VPP): The reseller must be listed as an authorized distributor.

  • If the manufacturer does not participate in VPP: No additional validation is required unless specified in the subcategory or SIN instructions. By accepting the terms of the MAS Solicitation, the contractor certifies authorization to distribute the offered products.

Implications for Industry:

This change significantly reduces the administrative burden for many MAS contractors, particularly those in categories outside IT and specialized equipment. It streamlines the process for adding new products to contracts and reduces the time and effort required to obtain and maintain LOS documentation.

However, contractors must remain vigilant about ensuring they have proper authorization from manufacturers, as the underlying requirement to be authorized distributors remains in place. This is especially important for manufacturers participating in VPP, as unauthorized resellers will not be permitted to offer those products under the MAS program.

Transactional Data Reporting (TDR): Expansion and Mandatory Participation

Another major change in Refresh 27 is the expansion of the Transactional Data Reporting (TDR) program. TDR requires contractors to report detailed sales data for orders placed under their MAS contracts, providing GSA and customer agencies with greater transparency into pricing and contract performance.

What’s Changing:

• End of the TDR Pilot:
  The TDR pilot is officially ending with Refresh 27. TDR will become mandatory for all existing Product SINs and the Cloud SIN (518210C).

• Mandatory TDR for 177 SINs:
  With Refresh 27, TDR will be mandatory for any MAS contract that includes one or more of the 177 TDR-eligible SINs. This includes both products and some services.

• Future Expansion:
  The remaining SINs not covered by Refresh 27 will become mandatory TDR SINs in a future refresh, planned for FY26. At that point, TDR will be mandatory for all MAS contracts.

• Effective Date:
  The requirement to report TDR data will take effect on the first day of the next sales reporting quarter (October 1, January 1, April 1, or July 1) following the execution of the “Participate in TDR” modification. This ensures a smooth transition and gives contractors time to establish internal processes for data collection and reporting.

• Price Reductions Clause (PRC) Liability:
  PRC liability ends on the first day of the next sales reporting quarter following the execution of the TDR modification. Contractors will no longer need to track and report price reductions under the PRC for TDR-eligible SINs.

• Reporting Requirements:
  Contractors will be required to submit 12 mandatory data fields for TDR reporting, with 4 additional optional fields. The manufacturer name and part number are required for products, but not for services.

• Contract-Level vs. SIN-Level:
  Once a contract transitions to TDR, all SINs under that contract become subject to TDR requirements. Each contract is treated separately; if a vendor has multiple contracts, TDR status is determined on a contract-by-contract basis.

Implications for Industry:

The expansion of TDR to nearly all MAS SINs represents a significant shift in how contractors report sales and pricing data. While this increases transparency and reduces the burden of PRC compliance, it also requires contractors to implement robust data collection and reporting processes.

Contractors should:

• Prepare for Mandatory TDR:
  Ensure that internal systems can capture and report the required data elements for all TDR-eligible SINs.

• Monitor Effective Dates:
  The transition to TDR will be tied to the sales reporting quarter, so contractors must be ready to begin reporting on the specified date.

• Understand PRC Implications:
  PRC liability ends for TDR-eligible SINs, but contractors must continue to comply with all other contract terms and conditions.

• Attend GSA Webinars and Training:
  GSA will provide additional guidance and training to help contractors navigate the transition.

Additional Key Changes in Refresh 27

While the LOS and TDR changes are the most significant, Refresh 27 includes several other important updates:

1. Retirement of Select SINs

GSA is retiring 10 SINs from the MAS program as part of its initiative to “rightsize” the MAS program by eliminating SINs with insufficient market demand or where administrative costs outweigh procurement benefits. Many of these items are available through other procurement channels as illustrated below.

2. Clarification of Out-of-Scope Items

Refresh 27 clarifies that certain items are out of scope for the entire MAS program, regardless of SIN. This includes personal hygiene products, automotive parts, fully assembled aircraft, books and publications (except technical publications), children’s toys, promotional products, sporting goods, general clothing (except workwear, uniforms, and protective apparel), swimming pool equipment, musical instruments, and customizable awards.

3. Updated Service Contract Labor Standards (SCLS) Wage Determinations

GSA is incorporating updated wage determination (WD) indexes in accordance with current policy. There are no clause or policy changes to the application of SCLS at this time, but contractors must ensure their pricing and WD numbers are up to date.

4. Changes to Price Proposal Templates

The price proposal template for products is being updated to clarify how accessories should be published on GSA Advantage!. Accessories published on GSA Advantage! are available for purchase alone or with a base product, unless specified otherwise in the contractor’s Text File.

5. Clarification of Stand-Alone Items

Stand-alone items must be proposed as either a base item or an accessory; they cannot be proposed as an option.

6. Waiting Period for Resubmission

For contractors who may lose their MAS contract due to lack of sales or other compliance issues, the waiting period for resubmitting an offer after a contract is canceled or expires due to low sales or non-compliance is being extended from 12 to 24 months for offers submitted after Refresh 27 is issued.

Conclusion

GSA MAS Solicitation Refresh 27 brings significant changes.  The new LOS requirements focus LOS authorization documentation on IT and printing/photographic equipment, while reducing that requirement for other product SINS.  The expansion of TDR to nearly all MAS SINs marks a major shift in how contractors report sales and pricing data, while reducing compliance challenges with the Price Reduction Clause.

Contractors should proactively review their contracts, update internal processes, and stay informed about GSA guidance. By doing so, they can ensure compliance and fully leverage the opportunities offered by the updated MAS program.

Have questions about TDR, LOS, or how these changes impact your business?

Or maybe you need help with modifying your GSA Contract?  Contact us to discuss your needs.