No. Under MAS Refresh 33, dated October 2, 2026, GSA can reject a past performance reference if the customer is a company you partially own, wholly own, or are affiliated with. GSA can also now ask for invoices and contracts to prove each project in your Relevant Project Experience is real.
What changed for past performance in Refresh 33?
Two sentences changed in SCP-FSS-001 (SEP 2026). In Factor Two, Past Performance, GSA added affiliates to the list of customers it can reject as references. In Factor Four, Relevant Project Experience, GSA added the right to request documents that prove a project is legitimate.
| Factor | Refresh 32 said | Refresh 33 says |
|---|---|---|
| Factor Two: customer references | GSA may reject a reference if the customer is an entity the offeror "partially or wholly owns" | GSA may reject a reference if the customer is an entity the offeror "partially owns, wholly owns, or is an affiliate" |
| Factor Four: project experience | GSA may reject a reference it believes is falsified or whose customer the offeror owns | GSA "may request supporting documentation (e.g., invoices, statements of work, SF 1449, subcontract agreements, etc.)" and may reject any project it reasonably believes is falsified |
You will not find either change in GSA's Significant Changes document for Refresh 33. I found them by comparing the Refresh 32 and Refresh 33 solicitations line by line. They sit in Section I, on pages 11 and 12 of the Refresh 33 solicitation.
Who counts as an affiliate?
The solicitation points to the definition in FAR 2.101. In plain terms, two companies are affiliates when one controls or can control the other, or when a third party controls or can control both. Ownership is one way to control a company. It is not the only way.
- Parent and subsidiary. Your parent company, or a company you own a controlling share of.
- Sister companies. Two companies under the same owner.
- Common control. Companies run by the same people, even where the ownership paperwork differs.
The old wording only covered customers you owned. A sister company slipped through, because you do not own your sister company. The new wording closes that gap. You can read the definition at FAR 2.101.
Why did GSA make this change?
A past performance reference is supposed to be an independent customer telling GSA how you performed. A customer under the same control as you is not independent. GSA is closing the door on references that are, in practice, a company vouching for itself.
When I was a Contracting Specialist reviewing offers, the references that worried me were the ones where the customer's point of contact shared a last name, an address, or an email domain with the offeror. The Refresh 32 text reached those references only when the offeror owned the customer. Now affiliation is enough.
There is a second reason, and it is my read, not GSA's statement. Refresh 33 also added a supply chain risk evaluation that reviews "corporate ownership, control, affiliation, and subsidiary relationships." GSA is now looking at your corporate family with screening tools. A reference from inside that family is easy to spot.
What proof can GSA ask for on project experience?
Invoices, statements of work, a signed SF 1449, and subcontract agreements. GSA already had this right for customer references under Factor Two. Refresh 33 extends it to the project narratives under Factor Four, so every project you describe should be one you can document.
Factor Four already required you to upload a copy of the Statement of Work, Performance Work Statement, Statement of Objectives, signed SF 1449, or subcontract agreement for each project. What is new is the follow-up request. Have these ready for every project before you submit:
- The contract or order. Signed, with the period of performance and dollar value.
- The statement of work. It should match what your narrative says you did.
- Invoices. Enough to show the work was performed and paid.
- The subcontract agreement. If you were a subcontractor, the agreement with the prime.
- A customer contact who will answer. Name, phone, and email that work today.
Across our 70+ GSA contract awards, the projects that drew questions were rarely fake. They were real projects described loosely, where the narrative claimed more than the statement of work supported. Write the narrative from the documents, not from memory.
What timing rules do your references still have to meet?
These did not change. Customer references must be ongoing or completed within three years of your offer date. Projects for Relevant Project Experience must be completed within the last two years or be ongoing. For an ongoing contract with option years, the base year must be finished.
| Requirement | Factor Two: Past Performance | Factor Four: Project Experience |
|---|---|---|
| How many | Three references from three distinct orders or contracts, through CPARS reports, questionnaires, or a mix | One relevant project for each services SIN |
| How recent | Ongoing or completed within three years | Ongoing or completed within the last two years |
| Ongoing contracts | Base year completed; first year completed for multi-year task orders | Base year completed; first year completed for multi-year task orders |
| GSA can request proof | Yes (already in Refresh 32) | Yes (new in Refresh 33) |
| Affiliate customer | Can be rejected (new in Refresh 33) | Rejected only if GSA believes the project is falsified |
Look at the last row. Refresh 33 removed the ownership language from Factor Four. That does not make an affiliate project a safe choice. It means GSA's stated ground for rejecting a project is falsification, and it now has the documents to test that.
Does this hit joint ventures and new companies hardest?
Yes. Joint ventures and companies inside a corporate family tend to have the most related-party work, so their easiest references are often affiliates. Those are now the references most likely to be rejected. Plan around it before you ask anyone to fill out a questionnaire.
Do not confuse two different things:
- An affiliate as your customer. This is what Refresh 33 targets. The affiliate bought from you and is vouching for you. GSA can reject it.
- An affiliate's own work used as your experience. This is a separate rule. Only Startup Springboard offerors can substitute work performed by affiliates, predecessor companies, or key personnel.
A joint venture that cannot show its own past performance can use past performance from its partners. My advice: pick reference customers with no ownership or control link to the venture or its partners. I cover the substitution rules in Can You Use an Affiliate's Past Performance in a GSA MAS Offer?
What Should You Do Now?
- Screen every reference for affiliation. Same owner, same officers, same address, or same parent means pick a different customer.
- Choose independent customers first. Federal, state, or commercial customers with no ownership or control link to you.
- Build a proof folder for each project. Contract, statement of work, invoices, and subcontract agreement.
- Write narratives from the documents. Every claim should trace to the statement of work.
- Check the dates. Three years for references, two years for projects, base year complete for ongoing work.
- Offer in progress? Recheck it against Refresh 33. A reference that passed under Refresh 32 may not pass now.
I spent eighteen years in federal acquisition as a Contracting Specialist and Contracting Officer at GSA, IRS, DoD, DOI, HHS, FTC, and Energy. I hold FAC-C Level III certification and a Master of Liberal Arts from Harvard University. If you want your references and project narratives checked against the Refresh 33 text before a Contracting Officer reads them, that review is part of our GSA Schedule program.
Frequently Asked Questions
Can my parent company or sister company be my GSA past performance reference?
Not safely. Under SCP-FSS-001 (SEP 2026) in MAS Refresh 33, GSA reserves the right to reject any reference where the referencing customer is an entity the offeror partially owns, wholly owns, or is an affiliate. Parent, subsidiary, and sister companies are affiliates under the control test in FAR 2.101.
What does affiliate mean in the GSA MAS solicitation?
The solicitation points to FAR 2.101. In plain terms, companies are affiliates when one controls or can control the other, or when a third party controls or can control both. Control can come from ownership or from shared management.
What documents can GSA ask for to verify my project experience?
GSA may request supporting documentation such as invoices, statements of work, a signed SF 1449, and subcontract agreements to verify the legitimacy of your relevant project experience. This request right is new for Factor Four in Refresh 33. GSA may reject any project it reasonably believes has been falsified.
Can I use work my affiliate performed as my own past performance?
Only under Startup Springboard. The MAS solicitation lets Springboard offerors substitute work performed by affiliates, predecessor companies, or key personnel, and Springboard is limited to FASt Lane participants. On a standard offer, the experience must belong to the entity submitting the offer.
How recent do GSA MAS past performance references have to be?
Customer references must be ongoing or completed within three years before you submit the offer. Projects used for Relevant Project Experience must be completed within the last two years or be ongoing. Refresh 33 did not change these timeframes.
Does an ongoing contract count as past performance for a GSA MAS offer?
Yes, if enough of it is complete. For an ongoing contract with a base year and option years, at a minimum the base year must have been completed. For a multi-year task order, at a minimum the first year must have been completed.
Were the past performance changes listed in GSA's Refresh 33 Significant Changes document?
No. GSA's Significant Changes document for Refresh 33 covers the supply chain provision and clause, the FASt Lane expansion, the Trade Agreements Act deviation, and product substitutions. The affiliate reference language and the Factor Four documentation language appear only in the solicitation text itself.