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How Do You Prepare Your GSA Schedule for FY2027? A Checklist for the CR Quarter

FY2027 started October 1, 2026 under a continuing resolution that runs only through December 11, 2026. That means a slow, cautious first quarter, and it also means your contract work has to be finished before agencies get full-year money. Accept the Refresh #33 mass mod, clean up your TDR reporting before January 1, 2027, and confirm SAM.gov, FCP, and your option dates now.

This follows our FY 2026 checklist, whose basics still apply. Below is only what is new this year, from 18 years as a Contracting Specialist and Contracting Officer at GSA, IRS, DoD, DOI, HHS, FTC, and Energy.

Where do FY2027 appropriations stand as of October 2026?

No full-year FY2027 appropriations bill has been enacted. Agencies are running on the Continuing Appropriations and Extensions Act, 2027 (H.R. 6500, P.L. 119-103), signed September 2, 2026. It funds operations at FY2026 levels from October 1 through December 11, 2026. Congress must pass full-year bills or another CR by then to avoid a funding gap on December 12.

ItemStatus
Funding vehicleContinuing resolution, Division A of P.L. 119-103
Signed into lawSeptember 2, 2026
CoverageOctober 1 to December 11, 2026 (72 days)
Funding rateContinues operations based on FY2026 levels (Sec. 101)
DoD limitsNo new starts (Sec. 102(a)(3)); no production rate increases above FY2026 (Sec. 102(a)(2))
Full-year billsNone of the 12 enacted

Sources: H.R. 6500 on Congress.gov, the White House signing statement, and CRS report R49353. December 11 falls after the November 3 midterm elections, so expect final FY27 numbers to be negotiated in a lame-duck session at the earliest. For where the request itself points, see our FY2027 budget request breakdown.

What does a continuing resolution mean for Q1 Schedule orders?

Under a CR, agencies can keep existing work funded but hesitate to start anything new. Expect renewals, option exercises, and recurring buys to keep moving, while new requirements slide toward the second quarter. Use October through December to win positioning, not to count on new obligations.

When I sat on the other side of the desk as a Contracting Officer, a CR quarter was when I did my market research and drafted requirements packages so they were ready the day full-year money landed. Contractors with clean pricing and current SINs caught that wave. If a lapse does happen on December 12, our shutdown guide covers stop-work orders and invoicing.

When do you have to accept the Refresh #33 mass modification?

GSA issued MAS Refresh #33 in early October 2026, and the mass modification must be accepted no later than 90 days after GSA issues it. If your mod is dated October 2, 2026, day 90 is December 31, 2026. Check the date on your own mod in eMod and calendar the deadline now.

  1. Log in to eMod and open the pending mass modification for Refresh #33.
  2. Read the significant changes document before signing, especially the new supply chain risk management provision and clause, FASt Lane expansion, and the product substitution language.
  3. If you sell products, note Class Deviation CD-2026-03, which removes the Trade Agreements Act exemption for Federal Prison Industries and AbilityOne participating nonprofits.
  4. If you hold SIN 517312 Wireless Mobility Solutions, review the three new subgroups. Placement is by request and GSA technical review, not automatic.
  5. Sign with the digital certificate of an authorized negotiator.

The new terms apply to orders and BPA calls issued after the mod's effective date. Orders already awarded stay under their original terms. See our Refresh #33 mass mod guide. As a Contracting Specialist, I saw unaccepted mass mods hold up later actions on the same contract far more often than contractors expected. Accept it before you file anything else.

What changes for TDR on January 1, 2027?

The MAS Transactional Data Reporting grace and trial periods run July 1 through December 31, 2026. Beginning with the reporting period effective January 1, 2027, compliance becomes subject to Contracting Officer enforcement. You have one quarter left to fix data errors without consequence.

RequirementRule
Reporting clauseGSAR 552.238-80, Industrial Funding Fee and Sales Reporting, Alternate I
Report dueWithin 30 calendar days after the end of each month
Zero-sales monthsMust still be reported
Industrial Funding Fee (IFF)Remitted quarterly; monthly payment is optional
Grace period endsDecember 31, 2026, regardless of when you accepted mass mod A909

Treat October through December reports as dress rehearsals and clear any soft flags. GSA's Help with TDR page lists the data fields, and our TDR grace period post explains who falls under which window.

Is your FCP Catalog Baseline blocking FY27 pricing changes?

It might be. Once your contract moves to the FAS Catalog Platform, you cannot submit new catalog-related modifications until the First Steps process is complete, and you have 60 days from system access to start the baseline. A stalled baseline freezes the pricing and SIN changes you want in place before Q2.

Our posts on FCP invitation waves and the baseline freeze cover the sequencing.

Is your SAM.gov registration ready for the new fiscal year?

FAR 52.204-13 requires you to stay registered in SAM.gov through final payment and to review and update your record at least annually. FAR 4.1201 makes your representations and certifications effective for one year. A lapse or a bad size representation can cost you a Q1 set-aside order.

Pull your entity record at SAM.gov first.

Where are you in your option period, and does your CPARS record support it?

MAS contracts run a five-year base and three five-year options. Under GSAR 552.217-71, the Contracting Officer considers the quality of your past performance when deciding whether to exercise an option. If your current period ends in FY27, your sales, compliance, and performance record are being read now.

What the regulation says is that past performance informs the option decision. How a CO actually reviews it is simpler: a contract with no sales, open compliance items, and unanswered emails is hard to justify extending. Our option period service exists for this window. Weak evaluations also hurt in competitions; see our CPARS screening post.

Should you file an Economic Price Adjustment before FY27 buying picks up?

If your costs rose, yes, but only through the EPA method in your contract. GSAR 552.238-120 requires requests to conform to the agreed method, and approved adjustments apply only to orders issued on or after the modification's effective date. Increases do not touch orders already awarded.

  1. Confirm which EPA method your contract states, such as established commercial pricing or a market index.
  2. Gather support that matches that method. The CO may use independent market research to accept, reject, or counter.
  3. Check that the FCP baseline is not blocking catalog changes before you submit.

An increase approved in November is in place when Q2 orders flow.

What should you update in GSA Advantage, eBuy, and your contract contacts?

GSAR 552.238-88 requires you to participate in GSA Advantage, and buyers judge you by what they see there. Before agencies get full-year funding, make your catalog, eBuy notifications, and contract points of contact accurate and reachable.

Which FY27 dates belong on your calendar?

Five Q1 dates matter to every MAS contractor. Put each on a shared calendar with a named owner, because a deadline nobody owns is a deadline that gets missed.

DateEventAction
October 22, 2026OCAS first FY27 pipeline reviewRegister on GSA Interact; see our OCAS post
December 11, 2026CR expiresWatch for full-year bills or another CR
90 days after issuanceRefresh #33 acceptance deadlineDecember 31 if your mod is dated October 2
December 31, 2026TDR grace and trial periods endFinal clean report cycle
January 1, 2027TDR enforcement beginsCO enforcement applies to reports from this period

What should you do now?

Across our 70+ GSA contract awards and more than 200 MAS contract holders supported after award, the contractors who win in Q2 are the ones who cleaned house in Q1. If you want a former Contracting Officer to run this checklist on your contract every month, look at our GSA Schedule maintenance program.

Frequently Asked Questions

Is the federal government funded for FY2027?

Only temporarily. The Continuing Appropriations and Extensions Act, 2027 (P.L. 119-103), signed September 2, 2026, funds agencies from October 1 through December 11, 2026 at FY2026-based levels. None of the 12 full-year FY2027 appropriations bills has been enacted.

Can agencies still place GSA Schedule orders under a continuing resolution?

Yes. Agencies can obligate funds under a CR for continuing operations, so renewals, option exercises, and recurring buys usually continue. New requirements are often delayed, and DoD is barred from new starts under the FY2027 CR.

How long do I have to accept the MAS Refresh #33 mass modification?

You must accept it no later than 90 days after GSA issues it. If your mod is dated October 2, 2026, that is December 31, 2026. Check the issue date on your own mod in eMod.

When does GSA start enforcing TDR compliance?

The MAS TDR grace and trial periods end December 31, 2026. Starting with the reporting period effective January 1, 2027, compliance is subject to enforcement by the Contracting Officer.

Can I submit a price increase during my FCP Catalog Baseline?

Generally no. Once your contract moves to the FAS Catalog Platform, you cannot submit new catalog-related modifications until First Steps is complete. Finish the baseline first, then file the Economic Price Adjustment under GSAR 552.238-120.

How often do I need to update my SAM.gov registration?

At least annually. FAR 52.204-13 requires you to review and update your SAM.gov information every year and stay registered through final payment, and FAR 4.1201 makes representations and certifications effective for one year.

Does past performance affect whether GSA exercises my MAS option?

Yes. GSAR 552.217-71 states that the Contracting Officer will consider the quality of your past performance when deciding whether to exercise an option.

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