FAR Updates Every Contractor Needs

Refresh 32 Tightens Past Performance Rules

In May of 2026 the General Services Administration (GSA) announced several proposed updates as part of Multiple Award Schedule (MAS) Refresh 32. These changes primarily focus on how companies can use past performance and project experience when pursuing a GSA Schedule contract. On June 1, 2026 one important update was removed from the refresh, which is:

Joint Venture Changes Have Been Postponed

GSA has officially removed all proposed Joint Venture (JV) changes from Refresh 32. This means the current JV requirements remain unchanged. According to GSA, any future modifications affecting Joint Ventures will be introduced in a later refresh. Contractors will receive advance notice before any new requirements become effective, giving businesses time to prepare.

For now, Joint Venture offerors can continue following the existing MAS solicitation requirements.

Tighter Rules for Using Experience from Other Sources

One of the most significant changes in Refresh 32 involves the use of customer references and relevant project experience. Historically, some offerors have relied on projects performed by predecessor companies or key personnel to demonstrate experience when the company itself had limited past performance.

Under the proposed Refresh 32 update, this flexibility will be significantly reduced.

Who Can Use Substituted Experience?

Going forward, only contractors participating in GSA’s Startup Springboard Program or Fast Lane Program will be permitted to substitute customer references and relevant project experience from:

  • Predecessor companies
  • Key personnel

For all other offerors, GSA expects submitted past performance information to be directly attributable to the company submitting the offer.

Clarification on Previous Work Substitutions

Refresh 32 also clarifies that approved substitutions may apply to both:

  • Past Performance Questionnaires (PPQs)
  • Customer references

This clarification removes uncertainty about where substituted experience may be used and establishes consistency across the solicitation requirements.

Increased Verification by GSA

Another noteworthy update is GSA’s decision to strengthen its verification authority. Refresh 32 adds language stating that GSA reserves the right to request additional documentation or information to confirm:

  • The legitimacy of submitted PPQs
  • The accuracy of customer references
  • The applicability of relevant project experience

In practical terms, contractors should expect greater scrutiny of supporting documentation and be prepared to provide evidence that validates their submissions.

New Definition of “Predecessor”

To reduce confusion, Refresh 32 introduces a formal definition of the term “predecessor.” While the final language will appear in the updated solicitation, the purpose is to clearly identify when a prior company relationship qualifies as a predecessor organization for past performance purposes.

This clarification is intended to create more consistent evaluations across all MAS offers.

What This Means for Contractors

These proposed changes signal GSA’s continued effort to strengthen the integrity of the MAS evaluation process. Companies with established corporate past performance are unlikely to experience significant impacts. However, newer businesses and organizations relying heavily on experience from former employers, acquired companies, or key personnel should carefully review the updated requirements.

Businesses participating in Startup Springboard or Fast Lane programs will continue to have greater flexibility when demonstrating experience. Other offerors should ensure their submitted projects and references clearly reflect work performed by the offering entity itself.

Refresh 32 does not introduce the anticipated Joint Venture changes, but it does place greater emphasis on validating corporate experience and ensuring that past performance submissions accurately represent the offeror’s capabilities. As GSA continues modernizing the MAS program, contractors should expect increased attention to documentation, transparency, and verification of submitted experience.

Organizations planning to submit a new MAS offer or modification should review the forthcoming SCP-FSS-001 language carefully and ensure their supporting documentation aligns with the updated requirements before submission.

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