MAS order flexibilities

To support the evolving needs of agencies and enable more order flexibility, our contracts offer several tools and authorities:

• Order-level materials allow agencies to add needed supplies or services that aren’t on the contract to supplement and support the main work.
• Contractor use of MAS contracts lets contractors purchase needed items from other MAS contracts to support an order quickly and efficiently.
• MAS Contractor Team Arrangements let two or more MAS contractors partner to combine their capabilities to jointly deliver a single, complete solution for complex requirements.

Order-level materials 

Get the definition for order-level materials.

If you choose to allow quotes to propose OLMs, ensure you:

• Can use OLMs with any order type — including fixed-price, time-and-materials, or labor-hour — unless your agency policy restricts it.
• Use OLMs to support and not lead. OLMs must not be the main purpose of the individual task order or delivery order.
• Clearly identify OLMs in the order as OLM products or services.
• Use existing contracts whenever possible. Authorize contractors to use products and services — including other MAS contracts — to the maximum extent possible to satisfy OLM requirements.
• Add additional requirements governing OLMs in the RFQ.

OLMs benefit you because they

• Increase your flexibility to purchase supplies or services necessary to support a total solution.
• Lower your agency’s procurement and administrative costs.
• Reduce contract duplication by eliminating the need to establish new commercial indefinite delivery indefinite quantity contracts or conduct open-market procurements for order-level other direct costs.
• Enable you to potentially realize savings through enhanced competition.
• Eliminate the need for government furnished equipment, reducing administrative overhead for you and contractors.
• Comply with MAS contract terms and conditions, such as the Trade Agreements Act, C-SCRM requirements, aligning with FAR and applicable requirements.
• Eliminate the cumbersome process of adding non-MAS (open-market) supplies or services to a MAS order.

Key tips for including OLMs

OLMs must be clearly identified in your order (see GSAR 538.7104-2(a)(2) (GSA CD RFO-2025-FSS-GSAR 538)). This means the line item needs to be identified by the contractor’s OLM SIN. To support visibility and administration of the order, we recommend creating separate line items for each OLM or sub-line items with sufficient description. Refer to FAR 4.202 (GSA CD RFO-2025-04) Uniform use of line items for direction on how to create line items.

Prior to placing your order, ensure that the MAS contractor’s contract has an OLM SIN. We are in the process of implementing the new FSS ordering procedures that went into effect in November 2025. As a result, not every MAS contract has been modified to allow for OLMs.

OLM SIN-level requirements and ordering instructions

Make sure you define and price OLMs at the order level according to GSAR 538.7104-2(a).

Remember: 

• OLMs must not be the primary purpose of the order.
• OLMs must be clearly identified in the order as items not on the contractor’s MAS contract or MAS BPA.
• A fair and reasonable price determination must be made for each OLM.
• Contractors may propose OLMs in response to an RFQ unless you have specifically prohibited their use in the solicitation, but they must clearly identify all OLMs in their quote.
• If you require a contractor to provide supplies or services from a mandatory government sources, include the 52.208-9 Contractor Use of Mandatory Sources of Supply or Services clause.

Evaluation

When placing an order, ordering activities must ensure that all proposed pricing — both direct and indirect — is fair, reasonable, and appropriate for the specific requirement.

Conducting cost or price analysis

You must evaluate order-level pricing to confirm it aligns with the scope, quantities, and conditions of the order. This analysis may include:

• Comparing proposed prices to historical prices paid for the same or similar items
• Reviewing published price lists or catalog pricing
• Assessing market research findings or commercial benchmarks
• Comparing against independent government cost estimates, or IGCEs

This step verifies that the order reflects the best value to the government and that pricing is consistent with current market conditions.

Evaluating indirect costs and OLM rates

Some orders may include indirect costs such as handling, overhead, or G&A. When these costs are proposed, you must:

• Review the indirect rates to ensure they are fair and reasonable
• Confirm that all approved indirect costs include the Industrial Funding Fee
• Verify that any indirect rate aligned with the contractor’s approved purchasing system is acceptable
• Recognize that a contractor may propose an approved handling or G&A rate for OLMs that was established at the order level

You may also allow for indirect costs associated with acquiring OLMs to be included as an OLM line item at the task order level. If indirect costs are approved for payment, you must document your determination that the rates are reasonable and appropriate for the order.

Approval of indirect costs requires you to review and determine that costs are fair and reasonable, and such costs must include the Industrial Funding Fee. An indirect rate in accordance with a contractor’s approved purchasing system is acceptable. A contractor may also propose an approved handling or general and administrative, or G&A, rate for OLMs established at the master contract level. If indirect costs are approved, you must make a determination that all indirect costs approved for payment are fair and reasonable.

OLMs and MAS BPAs

You can incorporate OLMs into orders placed against existing MAS BPAs only if all of the following apply:

• The underlying MAS contract includes the OLM SIN
• The OLMs are within the scope of the BPA and support work performed under other awarded SINs
• Utilizing OLM flexibility does not alter the BPA’s primary purpose or scope.

OLM requirements and supply chain risk

All OLMs you add at the task or delivery order level must:

• Be subject to the same terms and conditions of the MAS contract
• Comply with:
  • FAR 52.240-91 Security Prohibitions and Exclusions
  • FAR 52.225-5 – Trade Agreements
• Other applicable cyber or national security directives (e.g., EO 14028, CISA directives).

OLM evaluation checklist

When OLMs don’t meet the requirement

Here are some examples of when OLMs or other MAS contractor’s supplies and services should be used:

• A labor category or product needed for performance is available under another MAS contractor’s contract. You do not need to authorize MAS contractors when OLMs are acquired under GSAR 538.7102-1(e) (GSA Class Deviation RFO-2025-FSS-GSAR 538). This means you do not need to make a separate fair and reasonable price determination.
• When the item is available commercially but not on any contractor’s MAS contract, the contractor can source it under the OLM SIN and add it to the order.
• When MAS does not support the requirement (open market)
  • Until MAS has added OLM SIN to each SIN, you should continue to use open market items when required.
  • If the requirement includes items that are not eligible to be included on any MAS contract as an OLM and it is absolutely necessary to meet the requirement, you may for administrative convenience, add items not on MAS contract or MAS BPA to an individual task or delivery order issued against a MAS contract or MAS BPA or place a separate contract or order for those items.

Contractor use of MAS contracts

The MAS program is designed to give agencies and contractors maximum flexibility when fulfilling complex requirements. MAS contractors can seamlessly purchase products or services from other MAS contracts when needed to support an order. This built-in flexibility allows contractors to act on the government’s behalf to acquire essential items quickly and efficiently — without increasing supply chain risk, because MAS offerings are already competitively awarded and vetted.

Under GSAR 538.7102-1(e) (GSA Class Deviation RFO-2025-FSS-GSAR 538), no additional authorization is required when contractors obtain OLMs from other MAS contracts. MAS contracts also include FAR 52.208-90 Government Supply Sources (Deviation) which further enables contractors to access supplies and services across the MAS program. Together, these flexibilities streamline acquisition, reduce administrative burden, and help ordering activities meet mission needs with confidence.

Sales reporting and Industrial Funding Fee treatment when a MAS contractor buys from another MAS contractor

When a MAS contractor purchases products or services from another MAS contractor in order to support a customer order, the sale is reported and IFF charged and paid only once.

The selling contractor — the company that holds the MAS contract under which the item or service is sold — is the only contractor responsible for reporting the sale and including and remitting the IFF.

The procuring contractor — the company purchasing the item from another MAS holder — may not add an additional IFF to that purchase when billing the government (bill exact amount paid which must NOT exceed the selling MAS contractor’s final MAS price).

The buying contractor does not report the sale or pay the IFF.

How it works

Contractors will use the OLM SIN to invoice products or services procured through contractor use of MAS contracts.

File documentation requirements

• Contractors must maintain complete ordering files to support audit and compliance reviews by GSA or other authorized agencies.
• Contractor ordering files must include, at a minimum:
  • Documentation of competition or justification for limited sources (if applicable).
  • Price reasonableness determinations.
  • Copies of all quotes, communications, and award documentation.
  • Proof of compliance with applicable MAS clauses and restrictions.
• These records must be retained in accordance with the contract record retention requirements.

MAS Contractor Team Arrangements

Two or more MAS contractors can partner under MAS CTAs to combine capabilities to effectively fulfill larger, more complex requirements on a single requirement. MAS CTAs may be proposed in response to any opportunity under the MAS program unless you specifically prohibit it.