GETTING ON THE GSA SCHEDULE

GSA MAS Pricing: Pricing Disclosures, Price Support, and How GSA Evaluates Your Prices

The Commercial Sales Practices (CSP-1) format is no longer required for GSA Multiple Award Schedule (MAS) offers or modifications, but you still have to propose prices GSA can find fair and reasonable, and you still need to support them. Under the current offer instructions, you submit pricing on GSA’s templates, and the contracting officer can request commercial pricing support when the government’s own data do not settle the question.

What changed with Refresh 31?

MAS Refresh 31, issued in April 2026, made Transactional Data Reporting (TDR) mandatory for all MAS SINs and removed the CSP-1, the Most Favored Customer concept, and Basis of Award (BOA) tracking from MAS offers and modifications. In practice:

• You no longer prepare a CSP-1 or identify a “most favored customer” for a MAS offer or modification
• Price evaluation relies more on government data, such as prices paid, and on the pricing you propose
• After award, price risk is managed through TDR sales reporting and the TDR version of the price reductions clause, not through a BOA tied to your commercial customers

What pricing information do you still submit?

Your offer instructions, SCP-FSS-001, call for:

• GSA’s price proposal templates for the offerings you are proposing
• The Pricing Terms template, which captures the pricing terms for your offering
• Information supporting the “Commercial Market Price” for your offerings, as the instructions describe it
• Responses to any contracting officer requests for additional price support

The exact templates and fields change with refreshes, so use the current versions.

How does GSA evaluate your proposed pricing?

GSA looks for prices that are fair and reasonable. The contracting officer may compare your prices with other MAS contract prices, prices paid data, commercial market information, and your own records. If the analysis does not support your prices, the contracting officer may ask for support or negotiate. GSA does not guarantee that any proposed price will be accepted.

What about price reductions after award?

Under the TDR version of the price reductions clause, GSAR 552.238-81, contractors have obligations when they voluntarily reduce prices on the contract, or when GSA requests reductions, whether temporary or permanent. The clause no longer rests on a Basis of Award relationship with a particular commercial customer. For a contractor moving from the older approach, price reduction liability under the old clause ends on the first day of the next sales reporting quarter after the “Participate in TDR” modification takes effect. Your own transition date is contract-specific, so check your modification in eMod or ask your contracting officer.

Does accuracy still matter?

Yes. Prices, certifications, and support you provide are statements to the government, and inaccurate statements can have serious consequences under federal law. This page is general information, not legal advice. Raise specific questions with your contracting officer or qualified counsel.

How should you prepare?

1. Build your price list from records you can produce.
2. Keep your public price list, quotes, and GSA proposed pricing consistent.
3. Document discounts and rationale for any special pricing.
4. Decide how you will handle future price changes and reductions, including who approves them.
5. Train sales and finance staff on TDR and the price reductions clause.

TurboGSA can help you review your pricing package before you submit. Start with the TurboGSA FAQ.