GSA MAS Refresh 32 is now released, and four changes affect contractors directly: your contract now incorporates FAR 52.222-90 implementing Executive Order 14398 on DEI, GSA added the new Grants Management SIN 518210GM, it broadened the Health IT SIN 54151HEAL scope, and it barred architect-engineer (A/E) work under Environmental Consulting SIN 541620. The DEI clause is the one to act on immediately.
Refresh 32 is not my favorite refresh, but here we are. I spent 18 years across GSA, IRS, DoD, and DOI as a Contracting Specialist and Contracting Officer, and the mix in this one runs from a hard compliance obligation you cannot ignore to a genuine new revenue lane. Here is the practical breakdown, in order of urgency.
What is the most urgent change in MAS Refresh 32?
The DEI clause. Your contract now incorporates FAR 52.222-90, which implements Executive Order 14398. Your contract — and every order and BPA call placed under it — must be free of racially discriminatory DEI practices. This applies to existing orders, new orders, and BPA calls, which is why you should process the modification immediately.
FAR 52.222-90 pulls in the broad definitions of prohibited "racially discriminatory DEI activities" straight from EO 14398, and the FAR Council prescribed it at FAR 22.2203. From the CO seat, this is not a clause you negotiate — it flows down by mass modification, and noncompliance is an enforcement matter, not a paperwork one.
- Scope: the prohibition reaches existing orders, new orders, and BPA calls under your Schedule.
- Action: accept the mass modification promptly and review internal DEI policies against the EO 14398 definitions.
- Reference: see the FAR Council guidance implementing EO 14398 on Acquisition.gov.
What is the new Grants Management SIN 518210GM?
Refresh 32 adds SIN 518210GM, the Grants QSMO Marketplace SIN, covering SaaS award-management systems, grants-related IT tools, cloud services, and IT professional services that support federal grants management. If your firm does any grants-adjacent IT work, it is worth adding.
This is the rare new SIN that opens with almost no incumbents, which is exactly when you want to be on it. I wrote a full breakdown of the four subgroups, eligibility, and how to add it: What Is the New GSA Grants Management SIN (518210GM)?
What changed with the Health IT SIN 54151HEAL?
Refresh 32 broadened the scope of Health IT SIN 54151HEAL. If you previously tried to get on 54151HEAL and were denied — or your offerings did not fit the old narrow scope — the new language may now open the door.
The old description was thin and the subject-matter-expert review was subjective, so a lot of COs defaulted health work to the general IT SIN 54151S. The revision adds named categories like telemedicine, biomedical modeling, and clinical-process automation. Full detail here: GSA Expanded the Health IT SIN 54151HEAL.
Can you still do A/E work under Environmental Consulting SIN 541620?
No. Under Refresh 32, if you hold SIN 541620 (Environmental Consulting Services), you can no longer perform architect-engineer (A/E) projects under that SIN. A/E work is procured under separate authority, and GSA has drawn that boundary explicitly.
This one quietly catches firms that have been delivering design-adjacent environmental work under 541620. As a Contracting Specialist, I saw scope creep like this flagged in audits years after the order was placed. If your environmental practice touches A/E deliverables, separate that work now — do not run it through 541620.
| Refresh 32 change | Who it hits | First action |
|---|---|---|
| FAR 52.222-90 (DEI / EO 14398) | All contractors, all orders and BPA calls | Accept the mass mod now; review DEI policies |
| New SIN 518210GM (Grants Management) | Grants-adjacent IT firms | Evaluate an add-SIN modification |
| 54151HEAL scope expansion | Health IT firms, prior rejects | Revisit eligibility under new scope |
| 541620 A/E restriction | Environmental Consulting holders doing A/E | Move A/E work off 541620 |
How do you accept the Refresh 32 mass modification?
Refresh 32 is applied through Mass Modification A917 in the eOffer/eMod portal. You log in, review the mass mod, and accept it within the window stated in your notice. Add-SIN actions for 518210GM or 54151HEAL are separate modifications you file on top of accepting the refresh.
- Log in to eMod at the eOffer/eMod portal and open the pending Refresh 32 mass modification (A917).
- Read the incorporated clauses, including FAR 52.222-90, before you sign — this is your acknowledgment of the new terms.
- Accept within the deadline stated in your notice; late or ignored mass mods create real cancellation risk at the CO's discretion.
- File add-SIN mods separately if you want 518210GM or a revisited 54151HEAL.
What Should You Do Now?
- Accept the mass mod and handle DEI first. FAR 52.222-90 applies to existing and new orders and BPA calls — process it immediately and review your policies against EO 14398.
- Look at 518210GM. If you do grants-adjacent IT work, the new SIN is a low-competition lane worth adding.
- Revisit 54151HEAL. If you were denied Health IT before, the broadened scope may now cover you.
- Fix 541620 exposure. Stop running A/E projects under Environmental Consulting; separate that work.
- Do not sit on the mass mod. An unaccepted mass modification can put your contract at risk of cancellation.
Refresh 32 is a lot to absorb, and most of it lands on you through one mass modification. Blackfyre's contract management service is $299/month, and right now we are including an Add-SIN modification at no additional cost — a $2,500 value. You get a former GSA Contracting Specialist and Contracting Officer with a Harvard M.S., FAC-C Level III, and 18 years across GSA, IRS, DoD, and DOI actively managing your schedule and keeping you compliant. We have supported 70+ companies across every type of GSA transaction. See the proof of work and how the service runs at Blackfyre.
Frequently Asked Questions
What is GSA MAS Refresh 32?
Refresh 32 is the June 2026 update to the GSA Multiple Award Schedule solicitation, applied to contracts through Mass Modification A917. It incorporates the DEI clause FAR 52.222-90, adds the Grants Management SIN 518210GM, expands the Health IT SIN 54151HEAL, and restricts A/E work under Environmental Consulting SIN 541620.
What does FAR 52.222-90 require?
FAR 52.222-90 implements Executive Order 14398 and requires that your contract, every order under it, and every BPA call be free of racially discriminatory DEI practices. It applies to existing orders, new orders, and BPA calls, so contractors should accept the mass modification and review internal policies promptly.
Do I have to accept the Refresh 32 mass modification?
Yes. Refresh 32 is applied through Mass Modification A917 in eMod, and an unaccepted mass modification can lead to contract cancellation at the Contracting Officer's discretion. Review the incorporated clauses, including FAR 52.222-90, then accept within the deadline in your notice.
What is the new SIN 518210GM?
SIN 518210GM is the Grants Management / Grants QSMO Marketplace SIN added in Refresh 32. It covers SaaS award-management systems, grants-related IT tools, cloud services, and IT professional services supporting federal grants management, and it is open to grants-adjacent IT firms.
Can I still perform A/E work under SIN 541620?
No. Refresh 32 bars architect-engineer work under Environmental Consulting SIN 541620. If your environmental practice delivers A/E work, you must move it off 541620 and procure it under the appropriate A/E authority.
I was denied Health IT 54151HEAL before — should I reapply?
Likely yes. Refresh 32 broadened the 54151HEAL scope with named categories such as telemedicine, biomedical modeling, and clinical-process automation. A project that was borderline under the old language may now fit, so it is worth revisiting an add-SIN modification.