Short answer: no, not on a standard GSA MAS offer. Since Refresh 32 (June 4, 2026), SCP-FSS-001 lets an offeror substitute the work of affiliates, predecessor companies, or key personnel only under Startup Springboard, which is open only to FASt Lane participants. Everyone else must show past performance and project experience performed by the legal entity that is signing the offer.
I spent eighteen years in federal acquisition as a Contracting Specialist and Contracting Officer at GSA, IRS, DoD, DOI, HHS, FTC, and Energy. Borrowed experience is one of the most common reasons I watched otherwise solid MAS offers stall. Here is what the solicitation actually says, what a CO checks, and how to fix it before you submit.
What does the MAS solicitation say about affiliate experience right now?
The current instructions, SCP-FSS-001 (JUN 2026), limit affiliate, predecessor, and key-personnel substitution to Startup Springboard offerors in two places: Factor Two past performance references and Factor Four Relevant Project Experience. Outside Springboard, there is no provision that lets a parent, subsidiary, or sister company lend you its record.
- Factor One, Corporate Experience: a minimum of two years of corporate experience is required unless you submit under Startup Springboard.
- Factor Two, Past Performance: three CPARS reports, or a mix of CPARS and Past Performance Questionnaires (PPQs), from three distinct contracts or orders within the last three years. Substitution is labeled "Applicable to Startup Springboard Only."
- Factor Four, Relevant Project Experience: one project per services SIN, completed within two years or ongoing. Springboard offerors may substitute projects of affiliates, predecessors, or key personnel "that will be performing major aspects of the work."
- Definitions: the solicitation points to FAR 2.101 for "affiliate" and FAR 52.204-7 for "predecessor."
You can read the full text in the MAS solicitation 47QSMD20R0001 on SAM.gov. The past performance instructions no longer reference Open Ratings; it is CPARS or PPQs.
Who counts as an affiliate, parent, subsidiary, or predecessor?
Under FAR 2.101, affiliates are business concerns where one controls or can control the other, or a third party controls both. That covers parents, subsidiaries, and sister companies. A predecessor is different: it is an entity your company replaced through acquisition, merger, or similar succession, as defined in FAR 52.204-7.
| Relationship | Standard MAS offer | Startup Springboard offer |
|---|---|---|
| Parent company's contracts | Not allowed | Allowed with meaningful-involvement narrative |
| Subsidiary's contracts | Not allowed | Allowed with meaningful-involvement narrative |
| Sister company (common owner) | Not allowed | Allowed with meaningful-involvement narrative |
| Predecessor company | Not allowed since Refresh 32 | Allowed with narrative |
| Key personnel's prior projects | Not allowed as the project | Allowed with narrative |
| Joint venture partner | Allowed only when the JV is the offeror | Allowed |
Every entity in that table has its own Unique Entity Identifier (UEI) in SAM.gov. The MAS contract is awarded to one UEI. That is the entity whose record GSA evaluates.
Who qualifies for Startup Springboard?
Per GSA's Startup Springboard page, Springboard is for offerors with fewer than two years of corporate experience providing the offered products or services, and it is limited to FASt Lane participants. Today that means Information Technology category offers that are agency-sponsored. You opt in inside eOffer.
- Confirm you have less than two years of corporate experience in the offered scope. An older company can still qualify if its experience in that scope is under two years.
- Qualify for FASt Lane, which currently requires IT Large Category offers with agency sponsorship.
- Answer yes to "Do you have less than two years of Corporate Experience?" in eOffer.
- Be ready for the CO to request alternate financial documentation, such as a corporate guarantee from a parent.
Watch Refresh 33. GSA rescheduled it to October 2026, and the draft SCP-FSS-001 (SEP 2026) states that Startup Springboard becomes available across all Large Categories, still limited to FASt Lane participants. Until the final refresh posts, plan against the June 2026 text.
What does "meaningfully involved" mean to a Contracting Officer?
It means the offer shows, specifically, which affiliate people, systems, or resources will perform your MAS work. General statements that you are part of a larger family of companies do not meet it. GAO applies the same test across federal procurements, and it keeps sustaining protests when agencies credit vague affiliate claims.
- MetroStar Systems, Inc., B-416377.5 (Apr. 2, 2020): generalized references to a corporate "team" were too vague to show meaningful involvement of the affiliates.
- Battelle Memorial Institute, B-424575 (Sept. 10, 2026): GAO sustained because the awardee's proposal did not articulate what resources or services the affiliate would provide.
- The underlying rule: an agency may attribute a parent's or affiliate's record only when the proposal shows those resources will affect contract performance.
Those are FAR Part 15 cases, and FAR 15.305(a)(2)(iii) names predecessor companies, key personnel, and subcontractors performing major or critical aspects. Affiliates are not in that list. The MAS solicitation is narrower still, which is why the Springboard carve-out is the only door.
What documentation does a CO need to accept substituted experience?
A Springboard narrative must name the entity or person that performed the work and explain how they will perform your MAS contract. GSA may also request invoices, statements of work, an SF 1449, or subcontract agreements to verify any reference. Build that file before you submit, not after the clarification request.
- Relationship proof: an organizational chart showing ownership and control between the offeror and the affiliate.
- Commitment document: an intercompany or subcontract agreement committing named affiliate staff or resources to MAS orders.
- Named people: resumes for key personnel, with their role on the prior project and their role on your MAS contract.
- Project evidence: the SOW, PWS, or signed SF 1449 for the substituted project, plus the dollar value relevant to the SIN.
- Crosswalk paragraph: one sentence per SIN tying the affiliate's prior work to the services you are proposing.
When I was a Contracting Specialist at GSA reviewing Technical Proposals, the first thing I compared was the contractor name on the award document against the offeror name in eOffer. If they did not match, I stopped reading the narrative and started drafting a clarification. A mismatch you explain up front reads as transparency. A mismatch I discover reads as a problem.
What are the most common rejections tied to affiliate experience?
Most rejections come from one of five patterns: a non-Springboard offer using a parent's contract, a PPQ completed by a customer the offeror owns, a narrative that never names the performing entity, a stale project, or an award document issued to a different legal entity. Each is avoidable with a document check before upload.
| What the CO sees | Why it fails | Fix |
|---|---|---|
| Parent's contract used on a standard offer | Substitution is Springboard-only | Use your own work or qualify for Springboard |
| PPQ from a company you own | GSA may reject references from entities the offeror partially or wholly owns | Use arm's-length customers |
| "Our family of companies" language | No meaningful-involvement showing | Name the entity, people, and tasks |
| Project older than the window | Projects must be ongoing or completed within two years; references within three | Swap in a current project |
| SF 1449 issued to another UEI | Work is not attributable to the offeror | Disclose the relationship or replace the project |
The Refresh 33 draft goes further on references: it adds that GSA may reject a reference when the referencing customer is an affiliate of the offeror. Treat affiliate-sourced PPQs as a dead end now.
Can a joint venture use its partners' experience instead?
Yes, when the joint venture itself is the offeror. SCP-FSS-001 lets a JV rely on its partners' past performance and project experience, with narratives naming the partner that performed the work. That is a separate path from affiliate substitution, and it does not let a partner borrow the JV's record for its own offer.
For mentor-protégé and socioeconomic JVs, the protégé or socioeconomic partner must carry at least one CPARS or PPQ and relevant project experience for at least one SIN. We cover structure in detail in our guide to joint ventures on the GSA Schedule.
What should you do now?
- Pull every contract you plan to cite and confirm the awardee name and UEI match the offering entity.
- If any project belongs to a parent, subsidiary, sister company, or predecessor, decide now: replace it, or qualify for Startup Springboard through FASt Lane.
- Replace any PPQ completed by a customer you own or control.
- For Springboard offers, write the meaningful-involvement narrative with named people, named tasks, and a signed commitment document.
- Assemble invoices, SOWs, and SF 1449s for every reference so you can answer a verification request within days.
- Check the final Refresh 33 text when it posts in October before you submit.
Across our 70+ GSA contract awards, the offers that moved cleanly were the ones where every reference traced back to the offering entity on paper. If you are unsure whether your experience counts, or you need to rebuild a Technical Proposal around your own record, talk to Blackfyre about your GSA Schedule offer and we will review it the way a Contracting Officer would.
Frequently Asked Questions
Can a subsidiary use its parent company's past performance on a GSA MAS offer?
Not on a standard offer. Under SCP-FSS-001 (JUN 2026), substituting an affiliate's work is limited to Startup Springboard offerors, who must be FASt Lane participants. A Springboard offeror must name the affiliate and explain how it will be meaningfully involved in performing the MAS contract.
Can a parent company use a subsidiary's contracts in its MAS Technical Proposal?
Only if the parent qualifies for Startup Springboard. Otherwise GSA evaluates the record of the legal entity that submits the offer, identified by its UEI. A contract awarded to the subsidiary is the subsidiary's experience.
What is Startup Springboard?
Startup Springboard lets offerors with fewer than two years of corporate experience submit a MAS offer using alternate documentation for corporate experience and financial responsibility. It is limited to FASt Lane participants, which currently means agency-sponsored IT category offers. The draft Refresh 33 instructions would extend it to all Large Categories, still limited to FASt Lane.
Can I use a PPQ from a customer my company owns?
You should not. SCP-FSS-001 states GSA may reject a reference if the referencing customer is an entity the offeror partially or wholly owns. The draft Refresh 33 text adds affiliates to that list.
Does FAR 15.305 let me use affiliate past performance on a MAS offer?
FAR 15.305(a)(2)(iii) names predecessor companies, key personnel, and subcontractors, not affiliates. GAO has allowed affiliate records in some procurements when the proposal shows the affiliate's resources will affect performance. For MAS, the solicitation's own Startup Springboard limits control.
What proof does GSA want for substituted experience?
The narrative must identify who performed the work and how they will perform the MAS contract. GSA may also request invoices, statements of work, an SF 1449, or subcontract agreements to verify a reference. Have them assembled before you submit.
Can a joint venture use its partners' past performance?
Yes. When the JV is the offeror and cannot show its own record, SCP-FSS-001 lets it use its partners' past performance and project experience, naming the partner that did the work. Mentor-protégé and socioeconomic JVs have minimum requirements for the protégé or socioeconomic partner.