FAR & Beyond: The Revolutionary MAS Overhaul
The June 26th FAR & Beyond blog highlighted the start of the formal rulemaking for the Revolutionary Federal Acquisition Regulation (FAR) Overhaul (RFO). In doing so, the blog introduced a related opportunity for revolutionary procurement reform: the Revolutionary Multiple Award Schedule (MAS) Overhaul (RMO).
The RMO is an opportunity to build on the RFO by streamlining processes, reducing administrative/procurement burdens for the General Services Administration (GSA) and its industry partners, and expanding access to cutting edge commercial capabilities to meet customer agency mission requirements. The RMO should be a collective effort. GSA can solicit recommendations for MAS reform from stakeholders across the procurement community. Here are some structural reform recommendations for the RMO:
- Review and streamline the MAS solicitation as discussed in the June blog. The solicitation is approximately 600 pages, indicating an overly complex set of requirements and instructions for offerors and contracting officers. This review should include eliminating, to the maximum extent practicable, terms and conditions inconsistent with commercial practices. Moreover, the solicitation includes links to additional documents, instructions, forms, and questionnaires for offerors, contractors, and contracting officers. It is a procurement spiderweb of requirements.
- Implement “evergreen” contracting. As discussed in our April 10 FAR & Beyond blog, an unintended consequence of the RFO effectively reduces MAS contract terms from the original 20 years to 10 years. The RFO authorizes 10-year Blanket Purchase Agreements (BPAs). However, MAS rules require contractors to maintain contract coverage—including option periods—for the full BPA period of performance. As a result, a contractor with nine years remaining on its current contract cannot compete for a 10-year BPA without first obtaining a new 20-year contract. This limits competition, reduces access to best-value solutions, and increases bid and proposal costs for GSA and industry. There is a simple, common-sense fix. GSA can issue an optional modification to the MAS contracts incorporating two additional five-year options. Contractors can choose whether to sign or not. This would solve the immediate competitive harm while providing GSA with time to develop and issue a comprehensive solution through the ongoing General Services Acquisition Regulation (GSAR) rewrite. There is no magic to the 20-year contract limitation. It was a purely discretionary policy decision made at the close of the last century. Finally, as each contract is awarded independently, there is no prejudice against any party.
- Implement Section 876, Increasing Competition at the Task Order Level, of the 2019 National Defense Authorization Act. See the December 4, 2020, FAR & Beyond blog. Section 876 promotes competition at the task order level by eliminating the duplicative, formulaic, and burdensome administrative activities of negotiating contract level pricing for services. Under Section 876, pricing and value is determined at the competitive task order level, where customer agency requirements meet best value solutions proposed by MAS contractors. Section 876 remains a commonsense, efficient and effective approach to professional services under the MAS program and any other multiple award indefinite delivery indefinite quantity services contract vehicle. It is never too late to embrace common sense procurement measures!
- Finalize the new GSAR ordering procedures for the MAS program. The new ordering procedures provide clear, concise, and understandable guidance for the award and issuance of task and delivery orders. Significantly, the new GSAR eliminates duplicative language from the old FAR version that is in the standard terms and conditions of each MAS contract. The rewrite recognizes that there is no need to repeat what is already in the contract. The GSAR also provides clear guidance and flexibility for the inclusion of order level materials in tasks orders. Finally, the new GSAR takes the shackles off BPAs, providing greater flexibility in the use of single award BPAs and allowing longer terms than the old, FAR-based five-year limitation. The new procedures provide an efficient, effective process for the competition and issuance of best value task and delivery orders.
These structural reforms are revolutionary. They promote competition, increase access to the commercial market, and deliver best value for customer agencies and the American people.
Finally, GSA’s best value legislative proposal for the MAS is a game changer. As GSA explains on its website, “This proposal would update the standard for the General Services Administration’s Multiple Award Schedule program to seek out the best value for the Government, rather than the ‘lowest overall cost alternative,’ which may not account for administration costs, product quality, delivery time and other factors.” The best value language will provide a 21st Century management framework for the MAS program, providing both flexibility and accountability to ensure the MAS program delivers for the American people. It is a pro innovation, pro taxpayer, pro commercial item, and pro competition provision.
Registration Now Open! 2026 Fall Training Conference
Registration is now open for the Coalition’s 2026 Fall Training Conference! Join us on November 18–19 at the Fairview Park Marriott in Falls Church, Virginia, for two days of timely discussions on the issues shaping the federal procurement landscape.
This year’s conference will once again bring together government and industry leaders to examine the latest developments in governmentwide and healthcare procurement. Attendees will hear directly from key government decision makers and industry experts while having the opportunity to connect with colleagues from across the procurement community.
We are excited to welcome former Congressman and current Holland & Knight partner Tom Davis, who will deliver keynote remarks examining the 2026 election results. Tom will provide an in-depth analysis of the results and their far-reaching implications for the federal market and procurement policy.
Coalition Defense Fellow and President of Etherton and Associates Moshe Schwartz will also return for his popular legislative and budget update. Moshe will break down the latest developments on Capitol Hill, including key legislative and funding issues, and discuss what government contractors should be watching as we head into 2027.
Additional agenda details will be announced in the coming weeks.
To register for the Fall Training Conference, click here.
Click here to Book your group rate for the Coalition’s Fall Training Conference at the Fairview Park Marriott.
Sponsorship opportunities are now available and are currently being secured. Organizations interested in showcasing their brand and supporting this premier procurement event are encouraged to review the 2026 Fall Training Conference Sponsorship Prospectus for additional information. If you have any questions or are ready to secure your sponsorship, please contact Heather Tarpley at htarpley@thecgp.org.
Thank You to Our Current Sponsors
GSA Announces $13B in Suspected Contractor Fraud
The General Services Administration (GSA) announced that its collaboration with the White House Task Force to Eliminate Fraud has uncovered more than $13 billion in suspected fraud by federal contractors. Examples cited by GSA include allegations of misrepresentation and falsifying records to obtain government contracts.
“Let this serve as a warning to any bad actors thinking of stealing from the federal government: we will catch you, we will work with law enforcement to ensure your arrest, and we will do everything in our power to help recover every dollar you stole,” said GSA Administrator Edward C. Forst.
Led by the Office of Government-wide Policy, GSA is conducting what it describes as an “unprecedented review” of “COVID-19 spending, 8(a) program integrity, contractor eligibility, bid rigging, cybersecurity false claims, bribery, and other contractor integrity risks.” GSA is referring suspected cases of fraud to the Office of Inspector General (OIG) or Department of Justice (DOJ) for investigation.
DOJ Fraud Division Prioritizes Government Procurement Fraud
The Department of Justice’s (DOJ) National Fraud Enforcement Division released a memorandum outlining its enforcement priorities, including a significant focus on government procurement fraud. According to DOJ, the Division’s mission is to prosecute fraud regardless of its size or complexity, with the Government Accountability Office estimating that the Federal Government loses between $233 billion and $521 billion annually to fraud.
The memorandum identifies five primary areas of enforcement: public trust and financial integrity, health care, internal revenue, global trade and commerce, and corporate misconduct.
Within its public trust and financial integrity efforts, DOJ identifies government procurement fraud as a “critical priority.” The Division plans to prioritize contracting fraud schemes involving defective pricing, bid rigging, self-dealing, bribery, product substitution, and billing fraud. DOJ noted that these schemes can reduce the quality of government services and, in some cases, threaten national security and military readiness.
The Division will also prioritize fraud involving Federal benefit and grant programs and continue its focus on corporate misconduct. According to the memorandum, DOJ intends to hold organizations accountable for wrongdoing while rewarding companies that voluntarily self-disclose, cooperate, and remediate.
The Fraud Division is also expanding its workforce and capabilities. DOJ expects the Division to reach approximately 500 attorneys and staff and plans to continue growing over the next two years, with increased use of data science and technology to support fraud detection and prosecution.
DOL Finalizes Changes to Federal Contractor Affirmative Action Requirements
HR Dive reports that the Department of Labor (DOL) Office of Federal Contract Compliance Programs has issued three final rules implementing Executive Order (EO)11246 ending certain affirmative action requirements for federal contractors related to women, minorities and people with disabilities. In accordance with the EO, the final rules rescind the race- and sex-based affirmative action and requirements and make related changes to regulations under Section 503 of the Rehabilitation Act and the Vietnam Era Veterans’ Readjustment Assistance Act (VEVRAA).
Key changes include the:
- Elimination of race- and sex-based affirmative action requirements for federal contractors
- Removal of the 7 percent utilization goal for employment of individuals with disabilities under Section 503
- Revisions to contractor coverage thresholds under Section 503 and VEVRAA
The rules do not eliminate federal, state, or local anti-discrimination requirements. Contractors remain subject to applicable protections under Title VII of the Civil Rights Act and must continue certain obligations related to employment of individuals with disabilities under Section 503.
Invest in Success: Coalition Compliance Training Conference, October 7
Join us on October 7 at CGI Federal in Arlington, VA, or virtually, for the Coalition’s inaugural Invest in Success: Coalition Compliance Training Conference. This half-day training brings together government, industry, and legal experts to provide practical insights on evolving procurement policies, compliance requirements, and emerging risks facing federal contractors. Designed for contract, compliance, legal, ethics, and risk management professionals.
View the agenda below! To register, click here. For any assistance with registration, please contact Mady Whiting at mady.whiting@thecgp.org.
Procurement in the Age of AI: Ethics & Compliance in a Changing Federal Marketplace
The conference will feature a keynote session, “Procurement in the Age of AI: Ethics & Compliance in a Changing Federal Marketplace,” presented by Jessica Tillipman, Associate Dean for Government Procurement Law Studies at The George Washington University Law School. The session will examine emerging AI-related risks across the procurement lifecycle and supply chain, including organizational conflicts of interest, AI-enabled fraud and False Claims Act exposure, algorithmic collusion, system manipulation, and over-reliance on automated judgment. It will also explore practical compliance considerations for contractors as AI becomes increasingly integrated into their organizations, subcontractors, and federal procurement activities.
Active Bystandership: The Missing Link in Corporate Risk Reduction
Attendees will also hear from Jonathan Aronie, Partner at Sheppard, during “Active Bystandership: The Missing Link in Corporate Risk Reduction.” Active Bystandership is a practical approach that equips employees with the skills and confidence to intervene early when they see a colleague moving toward a potential mistake or compliance problem. Already used in high-stakes environments including aviation, healthcare, law enforcement, and the military, the approach offers contractors another tool for strengthening organizational culture and preventing problems before they result in costly compliance or enforcement issues.
Compliance and the Civil False Claims Act
Chris Terranova, Assistant Director, Civil Fraud Section, Commercial Litigation Branch, Department of Justice; Alex Canizares, Partner at Vinson & Elkins; Terra Fulham, Special Counsel at Covington; and Tirzah Lollar, Partner at Arnold & Porter, will provide perspectives on the False Claims Act and key compliance considerations for government contractors.
Additional speakers from government and industry are being invited to participate, and more program details will be announced in the coming weeks.
New SBA Size Standards: Public Comments Requested
The Small Business Administration (SBA) has issued a proposed rule that would establish new size standards for 338 industry groups and industries. The proposed rule would significantly increase the number of businesses considered “small.”
SBA is seeking public comments on the proposed rule. Comments are due September 21, 2026. The Coalition is considering providing comments on this proposed rule. If you have input or feedback, you would like the Coalition to provide to the government, please email said feedback to Greg Waldron at gwaldron@thecgp.org by the end of the day September 11.
As part of the proposal, SBA would simplify its size standards by moving from nearly 1,000 individual standards based primarily on six-digit NAICS codes to 338 standards using a combination of four- and five-digit NAICS codes. SBA is also proposing to eliminate size standard exceptions and shift numerous industries from receipt-based to employee-based standards.
Updated VA MSPV Coalition Consult
The Coalition has updated its resource overviewing the VA’s Medical Surgical Prime Vendor Program and how to participate in the program.
To access it, visit https://thecgp.org/cgp-media-resources/coalition-consults/. (You will need to enter your username and password. For assistance, please contact Mady Whiting at mwhiting@thecgp.org or 202.331.0975.)
As a reminder, Coalition Consults on the following programs are available to members on our website:
- DoD Medical Materiel Enterprise Standardization Office (MMESO) program
- VA Med-Surg Prime Vendor (MSPV) program
- VA & DoD High Tech Medical Equipment (HTME) program
- VA Medical Device Implant program
- VA Non-Expendable (NX) program
- VA Durable Medical Equipment (DME) program
Again, if you need any help accessing these resources, please contact Mady Whiting. If there are any other programs that you would like for the Coalition to consider creating a Consult for, please contact Joseph Snyderwine at jsnyderwine@thecgp.org.
VA Deploys Federal EHR to Three Indiana Hospitals
MeriTalk reports that the Department of Veterans Affairs (VA) deployed its Federal Electronic Health Record (EHR) system at Fort Wayne VA Medical Center, Marion VA Medical Center, and Richard L. Roudebush VA Medical Center, along with 16 affiliated clinics, on August 22, 2026.
According to VA Deputy Secretary Paul Lawrence, the department has deployed the Federal EHR at 11 hospitals in 2026, nearly doubling the number of deployments completed during the previous five years. The Indiana rollout provides more than 102,000 veterans and 6,000 staff with access to the system.
VA plans additional deployments in Alaska and Ohio later this year and at 26 sites across 12 states in 2027. VA Press Secretary Quinn Slaven said the EHRM program is “back on track” following a nearly two-year pause, noting that VA has made more than 13,000 system improvements and reported zero outages over the past 12 months.
GSA PBS Announces New Hiring Push
GovExec reports that GSA’s Public Buildings Service (PBS) told staff in an internal notice last week that 142 new vacancies have been posted to USAJobs, “reflecting our continued growth and need for talented individuals.” According to the notice obtained by Government Executive, PBS is looking to hire construction managers, lease contracting officers, and building managers.
PBS previously reduced its workforce by approximately 45 percent between September 2024 and November 2025, totaling about 2,500 positions. The new hiring activity represents an effort to rebuild administrative capacity following those workforce reductions.
GSA Leads Effort to Implement Quantum-Resilience in Federal Systems
The latest GSA blog highlights the agency’s efforts to fend federal systems against emerging threats from quantum computing. Quantum computers, which operate using principles of quantum physics, could eventually be capable of breaking existing encryption methods.
The Administration’s updated Cyber Strategy and OMB Memorandum M-26-15 direct GSA to lead proactive efforts to protect federal systems. GSA is initially focusing on Physical Access Control Systems (PACS) and Federal Identity, Credential, and Access Management (FICAM) architecture.
GSA is updating FICAM systems to support quantum-resistant algorithms while maintaining compatibility with existing systems. These efforts also emphasize the ability to transition between multiple encryption methods as threats and technologies evolve.
For PACS, GSA is expanding the capabilities of its PACS testing lab to evaluate quantum-resistant technologies. The lab evaluates products for inclusion on GSA’s Approved Products List (APL), which federal agencies are required to use when purchasing PACS products.
GSA will also host the virtual 2026 Post-Quantum Cryptography Summit on September 16, bringing together government, academia, and industry to discuss the transition to quantum-resistant cryptography. To register, click here.
New DIU Bridge Program Looks to Accelerate Commercial Tech Adoption
MeriTalk reports that the Defense Innovation Unit (DIU) has launched the Bridge Program, a new initiative aimed at accelerating the adoption of innovative commercial technologies. The program was established through an August 17 memorandum signed by DIU Director Owen West.
The Bridge Program will address critical bottlenecks across three focus areas: classified infrastructure, cybersecurity accreditation, and test and evaluation. To improve access to classified infrastructure, DIU plans to open co-use classified facilities nationwide. The program has already contracted with 13 shared commercial classified facilities, although additional details have not yet been released. DIU will also pursue process improvements, rapid contracting, policy changes, and congressional support to further expand access to infrastructure for classified work.
To accelerate cybersecurity accreditation, DIU plans to “shift the risk management framework process to the left in prototype development,” allowing cybersecurity accreditation to begin earlier in the development cycle. The program also plans to use AI tools to help shorten accreditation timelines. Finally, DIU is developing an end-to-end testing approach for companies participating in its pipeline, providing testing opportunities throughout the contract lifecycle.
OFCCP Completes Overhaul of Federal Contractor Compliance Framework: Three Final Rules Rescind EO 11246 Regulations, Narrow Section 503 Affirmative Action Requirements, and Update VEVRAA Coverage Thresholds
By Kris D. Meade & Rebecca L. Springer; Crowel & Moring
On August 21, 2026, the Department of Labor’s Office of Federal Contract Compliance Programs (OFCCP) published three coordinated final rules that eliminate – from a regulatory perspective – federal contractor affirmative action requirements for women and minorities and narrow contractor affirmative action requirements regarding individuals with disabilities. The final rules: (1) formally rescind the implementing regulations for Executive Order (EO) 11246 effective October 26, 2026; (2) narrow Section 503 affirmative action requirements regarding individuals with disabilities, generally effective September 21, 2026; and (3) update VEVRAA coverage thresholds and enforcement procedures effective September 21, 2026.
Recission of the Regulatory Framework Underlying Executive Order (EO) 11246
Following President Trump’s January 2025 revocation of EO 11246 via EO 14173, the OFCCP has now formally rescinded the entire implementing regulatory framework underlying EO 11246. The rule rescinds 41 CFR Parts 60-1, 60-2, 60-3, 60-4, 60-20, 60-30, 60-40, 60-50, and 60-999. This eliminates:
- Written affirmative action program (AAP) requirements for race, sex, religion, and national origin;
- Availability and utilization analyses and placement goals for minorities and women;
- Analyses of personnel activity to determine whether there are selection disparities;
- Construction contractor participation goals and specifications;
- Pay transparency anti-retaliation provisions; and
- Sex, religion, and national origin discrimination guidelines.
This recission has been anticipated since President Trump issued EO 14173, and most government contractors and subcontractors have already discontinued their EO 11246 affirmative action programs. This rule is the Administration’s last step in eliminating federal contractor affirmative action obligations based on race or sex.
Significant Revision of the Section 503 Regulatory Framework
This final rule revises the regulatory framework underlying Section 503 of the Rehabilitation Act of 1973. The rule makes the following substantive changes to contractors’ and subcontractors’ affirmative action obligations regarding individuals with disabilities:
- Rescinds the previously required 7% utilization goal for individuals with disabilities and eliminates the need to develop job groups as previously required by the EO 11246 and Section 503 regulations;
- Eliminates the requirement to conduct the disability utilization analysis previously required by 41 CFR 60-741.45;
- Rescinds the obligation to solicit disability status from all applicants and from employees at time of hire and again every five years;
- Rescinds the disability data collection and reporting requirements previously required by 41 CFR 60-741.44(k);
- Updates the coverage threshold from contracts or subcontracts of $15,000 to contracts or subcontracts of $20,000; and
- Relocates administrative enforcement procedures from 41 CFR Part 60-30 (one of the EO 11246 regulations that is being rescinded) directly into the Section 503 regulations, with no change to enforcement authority.
In defense of these regulatory changes, in the final rule the OFCCP asserts that the obligation to invite applicants and employees to self-identify as an individual with a disability “require[s] contractors to make disability inquiries that the ADA explicitly forbids.” The OFCCP further contends that the 7% utilization goal should be eliminated because “while the Section 503 regulations state that the use of quotas is prohibited, contractors may, in practice, be induced to use quotas to meet the utilization goal.”
It is important to note that while the final rule significantly narrows government contractor affirmative action obligations regarding individuals with disabilities, contractors and subcontractors with 50 or more employees and a contract of $50,000 or more must still maintain a written Section 503 AAP and continue outreach and positive recruitment efforts.
Finally, the Section 503 final rule states that “if a contractor learns of an applicant’s or an employee’s disability without asking—for example, through unsolicited disclosure during the interview process or a request for reasonable accommodation—then the contractor may take additional affirmative action to ‘employ or advance in employment’ that individual consistent with Section 503.” The final rule further states that “DOL is not prohibiting contractors from exercising their own legal and business judgment about making disability inquiries consistent with the ADA,” which permits inquiries that are job related or are made for reasons of business necessity.
Minor Revisions to the VEVRAA Regulatory Framework
The OFCCP’s final rule revising the Vietnam Era Veterans’ Readjustment Assistance Act (VEVRAA) regulations makes only minor changes to contractors’ affirmative action obligations regarding protected veterans:
- Increases the coverage threshold from $150,000 to $200,000, consistent with the FAR Council’s October 2025 inflation adjustment;
- Relocates administrative enforcement procedures from 41 CFR Part 60-30 directly into the VEVRAA regulations, with no change to enforcement authority; and
Contractors with 50 or more employees and a contract of $200,000 or more must still maintain a written VEVRAA AAP. Notably, while the Section 503 final rule eliminates the obligation to report on the disability status of applicants, the revisions to the VEVRAA regulations do not eliminate the 41 CFR 60-300.44(k) obligation to report on veteran applicants and hires. As a result, contractors will still be required to track applicant data and solicit veteran status from applicants and hires.
What Should Federal Contractors Do Now?
- Discontinue EO 11246-based affirmative action programs for race, sex, religion, and national origin, if not already discontinued.
- Update Section 503 AAPs to eliminate the 7% utilization goal, utilization analyses, and disability data collection.
- Discontinue the practice of inviting all applicants and employees to self-identify as an individual with a disability and discontinue the use of Form CC-305 to collect this information.
- Continue to prepare VEVRAA affirmative action plans.
DHA CPT Data Now Available to Members
The Coalition has received a new Defense Health Agency (DHA) data set covering Current Procedural Terminology (CPT) codes for medical services and procedures performed during calendar year 2025.
The data includes procedure volumes by CPT/HCPCS code and identifies whether services were performed through direct care at Military Treatment Facilities (MTFs) or through the contracted private-sector TRICARE network.
Note: The DHA data is provided in aggregate and does not identify individual Military Treatment Facilities.
Members can request a customized report by providing the CPT codes most relevant to their business. The report will show the 2025 procedure volumes for each requested code, broken out between direct care MTFs and the private-sector TRICARE network.
If you are interested in requesting a report or learning more, please contact Michael Hanafin at mhanafin@thecgp.org.
GWAC/MAC Committee Meeting with GSA AAS, September 30
The Coalition’s GWAC/MAC Committee will host a meeting on September 30, at 10:00 AM (ET). Pete Burr, Assistant Commissioner of GSA’s Office of Assisted Acquisition Services (AAS) will provide an update on AAS and its current priorities, followed by an opportunity for dialogue and discussion.
The meeting will be held in person in the DMV area (location TBA). Virtual attendance will also be supported.
To register, click here. For any assistance with registration, please contact Mady Whiting at mady.whiting@thecgp.org
Note: This is a members-only event. If you see a message that says “Registration Not Available” please log in using your member account.