GSA released Solicitation Refresh 31 for the Multiple Award Schedule. The headline change: Transactional Data Reporting is now mandatory across every Special Item Number on the program.
That ends a decade-long pilot. TDR has been optional for most SINs since 2016. Refresh 31 closes that door.
What changes for contractors
Three things move:
- Pricing transparency. Every transaction under your MAS contract now reports unit-level data to GSA. Quantity, price, customer category, and SIN. No more rolling Commercial Sales Practices disclosures as your only data trail.
- Compliance lift. If you already had TDR turned on for some SINs, you know the operational cost. Now it applies to your full MAS portfolio. Reporting cadence is monthly.
- Pricing leverage shifts. GSA contracting officers will have transaction-level visibility into what you actually charge other federal customers. That changes the negotiation posture on every modification and recompete from here forward.
What to do this week
- Audit your reporting systems. If your current TDR pipeline only covers a subset of SINs, scope what it takes to cover the rest. Most contractors are looking at 60–90 days of work.
- Pull the refresh language. Read what Refresh 31 actually requires. Do not rely on summaries — the operational details are in the modification text.
- Brief your contracts team. Anyone touching your MAS contract needs to know this changed. Including subcontractors who flow data up to you.
Where to read it
GSA's MAS program page: gsa.gov/buy-through-us/products-and-services/multiple-award-schedule
I will track how this plays out across the federal health IT contractors on the MAS program. If you are working through the implementation and want a second set of eyes, the contact form is open.
