If you’re a Multiple Award Schedule contractor, mark your calendar. GSA’s Federal Acquisition Service is planning to issue Refresh #33 to Solicitation 47QSMD20R0001 in September 2026, and there’s one change buried in there that deserves more attention than a typical refresh: the elimination of a longstanding Trade Agreements Act exemption. Let’s break down what’s actually happening.
Right now, Federal Prison Industries and AbilityOne Participating Nonprofit Agencies get an exemption from the Trade Agreements Act, or TAA. Refresh 33 ends that exemption, if you work with either of these entities as part of your supply chain, this is the change to watch. It means TAA compliance requirements that didn’t apply before now will.
Other solicitation-wide changes
A few more updates apply across the entire MAS solicitation, not just one category: GSA is formalizing its supply chain risk management practices with a new provision and clause, this has been happening informally for a while. Now it’s getting written into the contract itself, which means more consistency and more transparency about what GSA expects.
- FASt Lane eligibility is expanding to the entire solicitation. If you haven’t looked into FASt Lane because your category wasn’t eligible before, that excuse is going away.
- Every Large Category solicitation attachment will get a new requirement in the “General Information” section about product substitutions.
- Service Contract Labor Standards wage determinations are getting updated to the most current rates.
Category-specific changes
A handful of categories have their own updates worth knowing:
In Facilities, SIN 238160 (Roofing Products and Services) is getting updated descriptions, and SIN 532490P (Lease/Rental of Pre-Engineered/Prefabricated Buildings and Structures) is getting revised, including a new subgroup and a modification to an existing one.
In Miscellaneous, the 4PL SIN description is getting a new note in its General Requirements section, and SIN 238910 (Installation and Site Preparation Services) is getting a new note added to its SIN instructions.
In Travel, SIN 531 (Employee Relocation Solution) has revised Statement of Work guidelines, and SIN 561510 (Travel Agent Services) has both a revised SOW and a revised Price Proposal Template.
Once the mass modification is issued, you’ll have 90 days to accept it. Don’t let that window close on you. One more thing to flag: these changes only apply to new task and delivery orders issued after the modification’s effective date, including BPA calls under existing agreements. Anything awarded before that date stays under the old terms. So this isn’t retroactive, but it does apply going forward, even on orders under BPAs you already have in place.
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