Contract Requirements and Modification Guidance

GSA issues policy to temporarily allow non-TAA compliant products under MAS contracts for select Federal Supply Classes (FSCs)

In response to the COVID-19 pandemic, demand for certain critical and essential supply items has increased exponentially. At this time, suppliers are unable to support the demand with Trade Agreement Act (TAA) compliant products.

To address the increased need and support our stakeholders, the GSA Senior Procurement Executive (SPE) has issued a Class Determination and Findings (D&F) citing non-availability as the basis for temporarily allowing the procurement of non-TAA compliant products under Federal Supply Schedule (FSS) contracts (also known as Schedules) for certain Federal Supply Classes (FSCs). See attachment 1 of SPE Memorandum 2020-11 [PDF - 3 MB], for applicable FSCs. These FSC groups are subject to change. Prior to submitting a modification, please refer to the SPE memo for the most up to date FSC groups and time frame for offering goods.

The following documents include mandatory instructions and templates that contractors must use when submitting a modification to temporarily add non-TAA compliant products to a MAS contract:

GSA issues policy to temporarily allow awarding Essentially the Same (ETS) products under Federal Supply Schedule (FSS) Contracts Pursuant to AbilityOne Purchase Exceptions for COVID-19 Response Critical products

Pursuant to FAR 8.002, Priorities for Use of Mandatory Government Sources, Federal customers must purchase products listed on the AbilityOne (AB1) Procurement List (PL) from AB1 nonprofit agencies (NPAs). Due to the COVID-19 pandemic, demand for certain critical and essential supply products which are listed on the PL have increased to the point that AB1 NPAs are not able to meet the demand for these National Stock Numbers (NSNs). To address the increased demand for select NSNs, GSA requested and received Procurement Exceptions (PEs) from AB1 in accordance with FAR 8.706 Exceptions are outlined in the Senior Procurement Executive (SPE) Memo 2020-10, Purchase Exceptions From the AbilityOne Program in Response to COVID-19, issued April 29, 2020 and SPE Memo 2020-10 Supplement #1, issued May 28th, 2020.

GSA FAS has temporarily provided an allowance for awarding Essentially the Same (ETS) products under Federal Supply Schedule (FSS), commonly known as Multiple Award Schedules or MAS, Contracts Pursuant to AB1PEs for GSA’s purchase of identified COVID-19 Response Critical products. Other ordering agencies (non-GSA) must pursue their own PEs and follow the procedures in FAR 8.706, Purchase Exceptions when ordering off of FSS Schedules.

The following documents include instructions and templates that vendors must use when submitting a modification to temporarily add ETS products to a MAS contract:

Your First Step!

Get started by downloading the GSA Schedule Contractor Compliance Checklist [PDF - 19 KB].

This checklist is provided as a tool to facilitate compliance with key Schedule contract terms and conditions and is not intended to limit or otherwise modify your responsibility to comply with all terms and conditions of your Schedule contract. If ambiguities arise between this document and the terms and conditions of your Schedule contract, the terms and conditions incorporated into your Schedule contract shall prevail.

If you have questions or require additional information relating to your contract, your primary point of contact is always your assigned Contracting Specialist or Contracting Officer.

Note: There are numerous private companies that provide GSA Schedule contract administration support services (for a fee) to GSA Schedule contractors. Those companies actively market their services to new contractors, and it is quite likely one or more of them will contact you in the near future. Some firms use “GSA” in their company name and email addresses, and sometimes their communications are worded in such a way that they appear to be official GSA correspondence. GSA is in no way affiliated with any private companies to provide contract administration support services. Any email communications from GSA employees will always come from an email address containing the following format:

Next Steps

Below is a list of clauses that require attention throughout the life of your contract. The clauses are listed in order of importance and will require action on your part. Please familiarize yourself with these requirements now. If you have any questions, please reach out to your assigned Contracting Officer or Specialist for assistance.

Notes have been provided for each clause to help you identify the action required and important features. Be sure to check out the full text of each clause in your contract.

It’s Time to Get Your Catalog Online

The following requires your immediate attention and is critical to your success as a GSA Schedule Contractor.

Key Component: Make sure your pricelist is in the required format and post your approved price list and catalog to GSA Advantage!®.

Product Requirements for GSA Advantage!®

GSA is committed to improving the customer experience and strives to ensure that government buying and selling is easy, efficient, and modern. Publishing accurate photos of offered items on GSA Advantage!® avoids buyer confusion and reduces returns. With so many products on GSA Advantage!®, making sure that your products have a detailed product name, thorough descriptions, and clear, high quality photos is important.

Contractors selling products under their MAS contract shall submit photos, as required in the Schedules SIN-MOL-Photo-UPC look up table on the VSC.

To best support the buyer community, please consider following the below best practices when posting photos.

  • Include more than one photo per product or accessory to show different views (up to 4). You will be required to identify which photo is the default (i.e. primary photo).
  • Primary photos should not not be a drawing.
  • Photo should show *only* the product that is for sale, with few or no props or accessories that are not included with the product. Inclusion of additional accessories not included with the product may confuse the buyer.
  • Photos should only contain text that is a part of the product.
  • Photos should *not* contain a company logo, unless it is part of a product’s branding and affixed to the product itself.

For additional guidance and technical requirements related to photo uploads, please visit the Vendor Support Center (VSC).

Clause I-FSS-600 states that you post a price list on GSA Advantage!® for customers to view. This clause also outlines the proper format for your price list.

Paragraph A of this clause details the requirements of maintaining your GSA schedule price list. Paragraph B of this clause details the content of the terms and conditions.

This clause also requires that the electronic price list be uploaded to GSA Advantage no later than 30 days after the award.

All prices on your price list are to be inclusive of the industrial funding fee (IFF) (discussed in further detail below).

For your reference, below is an example of how the .75% IFF is added to your prices. The majority of Schedule contracts use this methodology for calculating IFF, but be sure to review your contract to ensure you understand how to appropriately apply the IFF to your prices.

Example: The final Schedule contract award price is calculated as follows:

  • Negotiated price divided by (1 minus the IFF rate)
  • If the IFF rate is 0.75%, then 1 - 0.75% = 1 - 0.0075 = 0.9925.
  • The Schedule contract award price is calculated as the negotiated price divided by 0.9925.
  • For example, if the negotiated price is $100,000, the proper way to calculate the Schedule contract award price (assuming an IFF rate of 0.75%) is:
    • ($100,000 / 0.9925) = $100,755.67

Need help getting on GSA Advantage®? The Vendor Support Center GSA Advantage!® Vendor Start-Up Kit is a helpful tool that provides instructions to help you to learn how to upload your price list so that your company’s information is viewable on GSA eLibrary and GSA Advantage!®. Upon CO approval of your electronic file, you may begin to utilize GSA’s eBuy system to view current procurement opportunities and respond to Requests for Information (RFIs) and Requests for Quote (RFQs). It is important that you post your price list as soon as possible, but not later than 30 days after your contract award date, to gain access to potential opportunities to sell your company’s products and/or services.

Sales Reporting and Industrial Funding Fee Remittance

Key Component: You must track all sales made through your Schedule by Special Item Number (SIN), so that you can properly remit your IFF to GSA. There are two different ways in which Sales and IFF are tracked and remitted:

  • Transactional Data (Monthly Reporting) and
  • Commercial Sales Practices (Quarterly Reporting)

Both systems require reporting by Schedule and SIN. Under Transactional Data Rule Reporting, the contractor reports sales data monthly. Contractors have 30 calendar days following the completion of the month to report sales. Industrial Funding Fee (IFF) must be remitted to GSA within 30 calendar days following the completion of each quarter.

Under Commercial Sales Practices (Quarterly Reporting), the contractor submits Sales and IFF within 30 calendar days following the completion of each quarter.

Note: All Sales and IFF will be reported through the FAS Sales Reporting Portal (SRP) located at FAS SRP.


Need help? The sales reporting website includes a user’s guide. Please direct any questions about sales reporting and IFF to your Industrial Operations Analyst (IOA).

Key Component: As a Schedule contractor you must generate a minimum of $25,000 in sales during the first 24 months on Schedule and $25,000 in sales every year thereafter.

  • Clause I-FSS-639 outlines this requirement. As a Schedule contractor, you will receive periodic email notifications regarding compliance with the minimum sales criteria outlined in Clause I-FSS-639. During the first two (2) years of your contract, you may receive up to four (4) notifications. If you receive a Contract Sales Criteria notification during the first 24 months of your Schedule contract and later report sales in the sales reporting tool that are in compliance with Clause I-FSS-639, you will receive a retention letter acknowledging that you have satisfied the initial 24-month minimum sales criteria of $25,000.

    Need Help? GSA's Office of Small and Disadvantaged Business Utilization (OSDBU) – The OSDBU advocates for small businesses and helps connect them with nationwide procurement opportunities. Find OSDBU contacts in each of the 11 GSA regional offices.

Subcontract Reporting Requirements

These clauses reference how to report executive compensation and subcontract usage. If you are an “Other than small business” this clause requires attention throughout the life of your contract.

Review Clause 52.204-10 Reporting Executive Compensation and First-Tier Subcontract Awards:

This clause requires the contractor to report the compensation of its top executives in the System for Award Management (SAM) database (FAR provision 52.204-7) when the following circumstances apply:

  • In the contractor's preceding fiscal year, the contractor received:
    • 80 percent or more of its annual gross revenues from federal contracts (and subcontracts), loans, grants (and subgrants) and cooperative agreements;
    • $25,000,000 or more of its annual gross revenues from federal contracts (and subcontracts), loans, grants (and subgrants) and cooperative agreements; and
  • The public does not have access to the information through periodic reports filed with the Security and Exchange Commission (SEC).

If applicable, you are required to report the information outlined above by the end of the month following the month the contract award was made, and annually thereafter. Failure to report this information in accordance with the clause may result in contractual action being taken by GSA, and may affect your performance rating on this contract.

Modifications and Mass Modification Guidance

The clauses below outline the different types of modifications that will happen throughout the life of your contract. The main difference between modifications and mass modifications is that modifications are generally initiated by you, while mass modifications are those routinely generated by GSA and often associated with a solicitation refresh. These two types of modifications are used to keep your contract current and compliant.

Key component: Understand when you need to initiate a modification for your Schedule and when GSA will initiate modifications that may impact your Schedule.


  • Review the following MAS solicitation clauses:
  • GSA has developed a single MAS modification guidance, along with Price Proposal Templates. This guidance includes all modification types available in eMod and is meant to ensure that contractors are aware of the information needed to successfully prepare and submit modification requests to their Contracting Officer/Contracting Specialist (CO/CS). Please click below to download the MAS modification guidance and Price Proposal Templates.
  • A modification is required whenever a change is made to your Schedule contract. Most frequently, changes are made to products and/or services, prices, or terms and conditions. However, modifications are also required for administrative changes such as authorized negotiators, address(es), phone/fax numbers, and key personnel. When initiated by the contractor, modification requests must be submitted electronically using eMod after your company’s Contracting Administrator, often referred to as the Point of Contact (POC), first obtains a digital certificate. For information specific to your Schedule, please visit the Vendor Support Page, "Modification Options”.

    Should your firm need to modify your contract, please check your GSA Schedule Offerings page to make sure you are not missing any specific instructions related to your contract. Additionally, your company is responsible for keeping all authorized negotiators and agent delegations up-to-date in the system. For example, if you delegated pre-award responsibilities to a consultant or third-party agent and do not intend for these agents to represent your firm following contract award, you must specifically request that these agents be removed as authorized negotiators from your contract. Additional helpful information about processing modifications can be found through the eOffer/eMod Help Center.

Key Component: The following clauses are generally applicable to all Schedule contracts and should be clearly understood.

  • Review clause 52.222-26 Equal Opportunity:

    This clause requires that the Equal Opportunity Clause poster be displayed in a conspicuous place available to employees and applicants for employment. Subcontractors must similarly display the EEO poster. See the U.S. Equal Employment Opportunity Commission website for various versions of this poster. Contractors are also required to file the Equal Employment Opportunity EEO-1 Survey in accordance with the instructions found at U.S. Equal Employment Opportunity Commission Survey website.
  • Review clause 52.204-9 Personal Identity Verification of Contractor Personnel:

    This clause requires your company to comply with agency personal identity verification procedures identified in the contract that implement Homeland Security Presidential Directive-12 (HSPD-12), Office of Management and Budget (OMB) guidance M-05-24 and Federal Information Processing Standards Publication (FIPS PUB) Number 201.
Last Reviewed: 2020-08-13