GSA Is Removing the 20-Year Limit on MAS Contracts: What an Evergreen Schedule Means for You (Refresh 34)

GSA is removing the 20-year limit on Multiple Award Schedule (MAS) contracts. MAS Refresh 34, expected in November 2026, rewrites GSAR 552.238-116 so a healthy Schedule can keep rolling through five-year options with no end date. You still have to earn each option. Here is what the change does, what it leaves alone, and what to do if your contract is close to year 20.

I spent eighteen years in federal acquisition as a Contracting Specialist and Contracting Officer at GSA, IRS, DoD, DOI, HHS, FTC, and Energy. I exercised Schedule options, declined a few, and watched good contractors scramble to replace a contract that had simply aged out. This change fixes a structural problem instead of adding paperwork.

What is changing in GSAR 552.238-116 under MAS Refresh 34?

Today, GSAR 552.238-116, Option to Extend the Term of the FSS Contract, allows a five-year base period plus three five-year options, for a hard maximum of 20 years. The Refresh 34 draft, implementing GSAR Overhaul Wave 4, deletes the limit on the number of option exercises. GSA calls the result "evergreen contracting."

The draft Significant Changes attachment GSA posted for industry comment lists the term change first under the GSAR Part 538 modernization. The rest of the Wave 4 package is a cleanup of the clause set your contract carries.

You can read the current clause text at acquisition.gov, GSAM 552.238-116. Compare it against the final Refresh 34 language when GSA publishes it, because the draft is explicitly subject to change after the comment period.

Why did the 20-year cap exist, and why does GSA want it gone?

The cap was a holdover from the Federal Supply Schedule's pre-MAS structure, and it forced every long-tenured contractor to re-compete against itself through a new offer. GSA wants it gone because the replacement cycle consumed Contracting Officer hours without improving price, competition, or compliance.

When I sat on the other side of the desk as a GSA Contracting Officer, the year-20 replacement offer was pure overhead. The contractor already had a current catalog, a Transactional Data Reporting (TDR) history, and a clean sales record. We re-reviewed all of it to issue a different contract number for the same company selling the same things.

The costs fell on contractors:

• Contract number churn. Agencies had to re-point Blanket Purchase Agreements (BPAs) and task orders to a new number, or GSA had to award an overlapping contract to protect them.
• Lost history. GSA Advantage sales history, eLibrary listings, and CPARS references all attached to the old number.
• Dead time and no growth. The streamlined acquisition started 24 to 36 months out, and it cannot add Special Item Numbers (SINs), so expansion stalled during the handoff.

Does evergreen mean GSA will automatically renew my Schedule?

No. Evergreen removes the calendar ceiling, not the Contracting Officer's discretion. Every five-year option is still a unilateral government decision under FAR 17.207, and GSA still declines options for contractors who miss the sales criteria, ignore mass mods, or carry a stale catalog.

From the CO seat, the option decision came down to a short checklist. It will be the same checklist after Refresh 34, except the contractor now has an unlimited number of chances to fail it.

1. Sales criteria. The current clause requires $25,000 in reported sales within the first 24 months and $25,000 in each 12-month period after that. Refresh 34 moves this into new GSAR 552.238-194, Sales Criteria.
2. Mass modification acceptance. Contractors who have not accepted outstanding refreshes are flagged before the option package goes out.
3. Reporting currency. TDR or 72A reports and Industrial Funding Fee (IFF) remittances must be current under GSAR 552.238-80.
4. Catalog and pricing accuracy. The CO checks GSA Advantage and the Federal Catalog Platform (FCP) against the awarded pricelist under GSAR 552.238-77.
5. Administrative health. Active SAM.gov registration, current representations, no open Examination of Records findings under GSAR 552.238-83.

In eighteen years as a Contracting Specialist and Contracting Officer, I never saw an option declined for a contractor who was clean on all five. I saw plenty declined for item one alone.

What else is in the GSAR Overhaul Wave 4 clause cleanup?

Wave 4 deletes 41 GSAR provisions and clauses, removes eight FAS "homegrown" FSS clauses, and adds five new GSAR clauses numbered 552.238-190 through 552.238-194. The result is a 16-clause GSAR Part 538 set that absorbs the old I-FSS clauses you have been reading since award.

Your contract will carry these GSAR Part 538 clauses after the mass mod:

Wave 4 does not touch the ordering procedures in GSAR 538.71. Those came through Refresh 30 and are moving separately through rulemaking as GSAR Case 2026-G501, which closes for comment October 22, 2026.

What else rides along in MAS Refresh 34?

Three items beyond the term change matter to most contractors: the new AI safeguards clause GSAR 552.239-7001, the optional FSS Domestic End Product Certificate at GSAR 552.238-130 under Class Deviation CD-2026-04, and SIN-level changes to 561210FAC and 54151HACS.

• GSAR 552.239-7001, AI safeguards. A GSAR Part 539 clause protecting government data fed into large language model systems. It applies to Schedule contracts, not only IT SINs, so services contractors using AI tools on task orders are in scope.
• GSAR 552.238-130, FSS Domestic End Product Certificate. Optional. Lets product contractors certify items manufactured in the United States with domestic component cost above 75 percent, or foreign iron and steel below 5 percent for predominantly iron or steel products. It is a material representation subject to the False Claims Act, 31 U.S.C. 3729. GSA will not enforce or share the data until OMB clears the information collection.
• Covered nitrile gloves. Per an August 31, 2026 OMB memo, GSA intends to remove medical-grade nitrile gloves covered by DHS's PPE Safety Stock contract, after contacting affected contractors.
• SIN 561210FAC. The HVAC maintenance subgroup is removed. Standalone HVAC, fire alarm, fire suppression, and elevator maintenance remain allowable; standalone janitorial, plumbing, and electrical do not.
• SIN 54151HACS. The voluntary Incident Response subgroup phases out at the end of FY2027. Contractors should request placement in the Incident Handling and Event Management (IHEM) subgroup now.

The final solicitation will post in eOffer and on gsa.gov.

My contract expires within 36 months. Do I still prepare a streamlined acquisition offer?

Keep preparing it until GSA publishes the final Refresh 34 text and states in writing how the revised 552.238-116 applies to contracts already in their third option. The draft removes the cap going forward; it does not say whether a contract awarded under the old clause gets a fourth option after accepting the mass mod.

Ask your Contracting Officer this the week the mass mod posts. Three outcomes are possible:

1. Accepting the mass mod incorporates the revised clause, and your CO can exercise a fourth five-year option on the existing contract number. This is the clean result and the one GSA's "evergreen" framing implies.
2. GSA treats the revised clause as prospective only, and contracts awarded under the three-option version still terminate at year 20. You would still need the streamlined acquisition.
3. GSA issues a separate bilateral modification for contracts near expiration to adopt the new term.

My read, as someone who processed these: outcome one is the most likely, because a mass mod that incorporates a clause by reference changes the contract's terms. But "most likely" is not a plan when a contract number with $20 million of BPA history is attached to it. Keep the streamlined acquisition package assembled and do not submit it until your CO answers in writing.

What should contractors do before the Refresh 34 mass mod posts?

Use the next few weeks to make your contract option-ready, because the first thing a CO does after a refresh is run the compliance report. Clear the five option checklist items now, decide on the domestic end product certificate, and inventory where AI tools touch government data on your task orders.

• Pull your sales report. Confirm you exceed $25,000 in the trailing 12 months. If you are short, this is the only item that can cost you an option outright.
• Accept Refresh 33. The Refresh 33 mass mod (A920) posted in October 2026 with its own 90-day window. Two outstanding mass mods is a red flag on the option report.
• Reconcile FCP to your awarded pricelist. Out-of-scope items and expired prices are the most common Examination of Records finding I saw as a Contracting Specialist.
• Map AI usage. List every task order where staff use LLM tools with government data. GSAR 552.239-7001 will require safeguards; know your exposure before you accept the clause.
• Decide on GSAR 552.238-130. Product contractors with domestic manufacturing should run the component-cost math now; resellers may rely on OEM data but should keep the OEM statement on file.
• Check SIN exposure. If you hold 561210FAC HVAC-only or 54151HACS Incident Response, start the subgroup change in eMod.

If your Schedule is in its third option, or you are not sure which clause version your contract carries, our option-period support reviews the contract, builds the option-readiness file, and gets the written answer from your CO on how Refresh 34 applies to you.

What Is the Bottom Line?

• MAS Refresh 34, expected November 2026, removes the 20-year limit from GSAR 552.238-116. Schedules become evergreen, renewable in five-year options with no ceiling.
• Each option is still a Contracting Officer decision. Sales criteria, mass mod acceptance, TDR and IFF currency, and catalog accuracy decide it.
• Wave 4 deletes 41 GSAR provisions and clauses, drops eight homegrown FSS clauses, and adds GSAR 552.238-190 through -194.
• The same refresh brings the AI safeguards clause GSAR 552.239-7001, the optional domestic end product certificate GSAR 552.238-130, and SIN changes to 561210FAC and 54151HACS.
• Contractors inside 36 months of expiration should keep the streamlined acquisition package ready until GSA confirms in writing how the new clause applies to existing contracts.
• Accept the mass mod within 90 days. An unaccepted refresh is the fastest way to lose an option under any version of the clause.

Frequently Asked Questions

When does the 20-year limit on GSA Schedule contracts go away?

GSA plans to issue MAS Refresh 34 in November 2026. The revised GSAR 552.238-116 reaches existing contracts through the Refresh 34 mass modification, which contractors have 90 days to accept. The change is in draft until GSA posts the final solicitation refresh.

Will GSA automatically extend my Schedule once it is evergreen?

No. Each five-year option remains a unilateral government decision under FAR 17.207. GSA still evaluates sales criteria, mass modification acceptance, TDR and IFF reporting, and catalog accuracy before exercising an option. Evergreen removes the calendar ceiling, not the review.

What happens to a contract that is already in its third option when Refresh 34 posts?

The draft does not say. The most likely outcome is that accepting the mass mod incorporates the revised clause and allows a fourth option on the same contract number. Until GSA confirms that in writing, contractors within 24 to 36 months of expiration should keep a streamlined acquisition package ready.

What is the minimum sales requirement to keep a GSA Schedule option?

The current requirement is $25,000 in reported sales within the first 24 months after award and $25,000 in each 12-month period after that. Refresh 34 moves this requirement into new GSAR clause 552.238-194, Sales Criteria. Falling short is the most common reason a Contracting Officer declines an option.

Which new GSAR clauses are added in MAS Refresh 34?

Five new clauses: GSAR 552.238-190 Federal Supply Schedule Contractor Team Arrangements, 552.238-191 FSS Contract Requirements, 552.238-192 FSS Order-level Requirements, 552.238-193 Product Offering and Sales Requirements, and 552.238-194 Sales Criteria. They consolidate the old I-FSS homegrown clauses into the GSAR. GSAR 552.239-7001 on AI safeguards and the optional 552.238-130 domestic end product certificate are also added.

Is the FSS Domestic End Product Certificate mandatory?

No. GSAR 552.238-130 under Class Deviation CD-2026-04 is optional for offerors and contractors. A product qualifies if it is manufactured in the United States and more than 75 percent of component cost is domestic, or, for iron and steel products, foreign iron and steel is under 5 percent of component cost. The certification is a material representation subject to the False Claims Act.