The General Services Administration's Refresh 31 is the most significant restructuring of the Multiple Award Schedule (MAS) program in years. Three big changes: mandatory Transactional Data Reporting (TDR) across all special item numbers, new AI-related contract terms, and the elimination of the Price Reductions Clause. Schedule holders will receive a mass modification and have 90 days to accept. Coverage from Washington Technology and USFCR.
Change 1: Mandatory TDR everywhere
Transactional Data Reporting becomes mandatory on all 112 SINs that were previously exempt. TDR requires Schedule holders to submit transaction-level sales data to GSA on an ongoing basis — order details, prices, customer agency, and quantity.
The big upside: the Price Reductions Clause is being eliminated. Previously, contractors had to track every commercial price change and notify GSA if they offered a better price to any commercial customer. That tracking burden goes away.
Net effect for most firms: less commercial-pricing surveillance, more sales-data reporting. Larger Schedule holders with sophisticated TDR systems gain. Smaller firms may face higher reporting burden than they're set up for.
Change 2: AI provisions standardize across government
Refresh 31 incorporates provisions from OMB's M-25-22 memo (April 2025), creating government-wide standardized terms for AI-related services and products. The most consequential clause: vendors must obtain permission before using non-public government data to train their publicly-available AI algorithms.
For SaaS vendors with multi-tenant AI features, this is the operationally significant clause. Default training pipelines that ingest customer data must be auditable and gated for federal customers. Firms that haven't already implemented federal-customer data segregation in their AI training pipelines need to start.
Change 3: Open-market items restricted
Open-market items (products and services not on a vendor's Schedule contract but sold against an order) are being restricted. In their place, GSA is consolidating around the Order-Level Materials (OLM) SIN — a structured approach where ancillary items can be added to orders within defined rules.
For Schedule holders that frequently add open-market items: review your historical orders and identify how much revenue runs through this path. The OLM SIN restructure may require process changes.
What's also happening: program "rightsizing"
Separately, GSA announced a "rightsizing" initiative targeting:
- Schedule contracts that fail to meet minimum sales thresholds — these will be allowed to expire
- Contractors with documented non-compliance — likely terminations
- Redundancies with other procurement channels — consolidation
- Low-demand items — pruning
Schedule holders below sales thresholds need to act this quarter — either drive sales above threshold, or expect to lose the contract.
What to do this week
- Pull a copy of the Refresh 31 mass mod when it arrives. Don't sign without reading the AI clauses if you sell any AI-enabled product or service.
- Audit your last 12 months of Schedule sales against the TDR template. If you can't produce transaction-level data on demand, you're not ready.
- Audit open-market items in your historical orders. Plan a path through OLM SIN for any meaningful revenue stream.
- If your Schedule sales are below typical minimums (roughly $25k/year in many SINs), evaluate whether to re-up effort or let the contract expire.