If your company applied for a GSA Multiple Award Schedule contract more than a few months ago, the process you remember may no longer exist. MAS Refresh 31 made the Startup Springboard track mandatory for any applicant under two years old — including joint ventures, regardless of how experienced their partners are. Refresh 32 went further, allowing GSA to require a federal agency letter of support tied to a genuine upcoming opportunity. The change lands hardest on mentor-protégé JVs.
I spent eighteen years in federal acquisition as a Contracting Specialist and Contracting Officer at GSA, IRS, DoD, and DOI, and I hold a FAC-C Level III with a Harvard M.S. Across our 70+ proven GSA Schedule awards, I watch the IT Category solicitation refreshes closely, because they move faster than most contractors — and most consultants — track. These two refreshes changed the young-company on-ramp materially, and they did it quietly.
What changed for startups and JVs across MAS Refresh 31 and 32?
Two things changed. Refresh 31 forced every applicant under two years old, joint ventures included, onto the MAS Startup Springboard track and ended self-initiated FASt Lane. Refresh 32 added a possible agency letter-of-support requirement for Springboard applicants — proof that a specific agency wants you on Schedule for a real opportunity.
| Refresh | What it changed | Who it affects |
|---|---|---|
| Before 31 | JVs relied on partners' 2+ years of history to bypass the startup threshold | Any JV of established partners |
| Refresh 31 | Springboard mandatory for entities under 2 years; FASt Lane can no longer be self-initiated | Startups and all young JVs |
| Refresh 32 | Agency letter of support may be required for Springboard applicants | Springboard startups and JVs tied to a specific opportunity |
How did joint ventures qualify before Refresh 31?
Before Refresh 31, a joint venture could lean on its partners. If the JV's individual members had each operated for more than two years, the JV itself generally did not have to independently satisfy GSA's two-year business history requirement. A JV of two established firms was not treated as a startup.
That logic made sense. The two-year history rule exists to screen for financial and performance stability, and a JV formed by seasoned companies carries that stability through its partners. Under the SBA framework, joint ventures — including SBA Mentor-Protégé JVs under 13 CFR 125.9 — are built precisely to let a capable team compete as one entity. The old MAS reading respected that.
What did MAS Refresh 31 change for companies under two years old?
Refresh 31 removed the partner-experience workaround. Any applicant under two years old — including a joint venture, regardless of how long its individual partners have operated — must now apply through the MAS Startup Springboard process instead of the standard track. Refresh 31 also formalized agency sponsorship for FASt Lane, ending self-initiation.
Two concrete shifts came out of Refresh 31:
- Springboard became mandatory, not optional, for young entities. On its own this is not catastrophic — Springboard exists for exactly these companies, and the core application did not change dramatically. What changed is that experienced-partner JVs lost the ability to route around it.
- FASt Lane sponsorship became affirmative. A contractor can no longer self-initiate FASt Lane participation. An agency must demonstrate a clear, documented need for the specific contractor before eligibility applies. We cover that track in our guide on what GSA FASt Lane is and who qualifies.
As a Contracting Specialist reviewing MAS offers, I can tell you the two-year history check was never a formality — it was a stability screen. Refresh 31 simply moved every young entity into the track built to run that screen deliberately.
What new requirement did Refresh 32 add for Springboard applicants?
Refresh 32 introduced a new potential hurdle: in certain circumstances, a startup or JV applying through Springboard may now need a letter of support from a federal agency, affirming that the agency wants the company on Schedule because of a genuine, upcoming opportunity. It is no longer always enough to prove you are qualified — you may need to prove demand.
This is a materially different bar than existed a few months earlier. The old question was "is this company capable and stable?" The new question can be "is this company capable, stable, and wanted by a specific agency for a real requirement?" That second clause changes what "ready to apply" means.
The letter cannot come from you. It has to be written and signed by an authorized agency official and tied to a specific requirement. Because you cannot produce one on short notice, the agency conversation has to start early — the mechanics are in our companion piece on how to get an agency letter of support.
Why does this hit mentor-protégé joint ventures hardest?
Mentor-protégé JVs sit in the most ambiguous spot. By design, the JV is a new legal entity — but it pairs an experienced mentor with a small-business protégé specifically so the protégé can grow. GSA's newer rules were written with pure startups in mind, and reviewers are split on whether a JV backed by an experienced mentor should be judged by partner history or by the stricter startup framework.
From the CO seat, that split is exactly the kind of unsettled policy that produces inconsistent outcomes. I have seen the same fact pattern read two ways by two reviewers:
- The partner-experience view: a JV whose mentor has well over two years of qualifying performance is evaluated through that experience.
- The strict-startup view: the JV entity is new, so the newer Springboard framework applies regardless of partner history.
The policy is new enough that this has not fully settled. SBA Mentor-Protégé JVs are governed under SBA's Mentor-Protégé Program, and the protégé must still perform its required share of the work under 13 CFR 125.6 and FAR 19.703 — but how GSA weighs the mentor's history in a MAS Springboard review is the open question.
How should a JV position its Springboard application right now?
Do not assume GSA will apply the favorable interpretation by default. The strongest offers right now proactively argue how the JV should be evaluated — leaning explicitly on partner experience where that case exists — inside the application itself, rather than leaving the reading to the reviewer.
Practically, that means:
- Make the evaluation argument in writing. State how the JV should be assessed and why partner experience is the right lens, with the supporting performance evidence attached.
- Document each partner's qualifying history — the mentor's track record and the protégé's capability — so a reviewer taking either view has what they need.
- Line up an agency letter of support early if a specific opportunity exists, in case Refresh 32's requirement applies to your situation.
- Confirm your track before you build the package — standard, Springboard, or FASt Lane — because the entity structure, not the ambition, decides it.
What's coming with MAS Refresh 33?
GSA has signaled a further round of changes with Refresh 33 that may again affect how JV MAS contracts are evaluated or awarded. Industry pushback — especially from small businesses and mentor-protégé teams — makes it plausible that some of this policy gets revised or clarified before it settles.
That does not mean waiting. It means building an application resilient to more than one interpretation, so a mid-process rule change does not sink an offer you have already invested in. Watch the MAS solicitation refresh notices on SAM.gov for the exact effective language when Refresh 33 posts.
What Is the Bottom Line?
- Refresh 31 made Springboard mandatory for any entity under two years old, JVs included, and ended self-initiated FASt Lane.
- Refresh 32 can require an agency letter of support for Springboard applicants tied to a specific opportunity.
- Mentor-protégé JVs face the most ambiguity — reviewers are split between partner-experience and strict-startup readings.
- Argue your evaluation lens explicitly in the application; do not assume the favorable reading.
- Refresh 33 is coming — build an offer that survives a rule change, and confirm which track your entity actually falls under first.
Frequently Asked Questions
Do joint ventures have to use Startup Springboard now?
Yes, if the JV entity is under two years old — even when its individual partners each have more than two years of history. Refresh 31 removed the old partner-experience workaround and routes young JVs through the mandatory Startup Springboard track.
Does Refresh 32 require every Springboard applicant to get an agency letter of support?
Not every applicant. Refresh 32 allows GSA to require a letter of support in certain circumstances, generally when the application is tied to a specific upcoming agency opportunity. Because you cannot produce one quickly, treat it as likely and start the agency conversation early.
How are mentor-protégé JVs evaluated under the new rules?
Inconsistently, for now. Some GSA reviewers evaluate these JVs through the experience of their partners; others apply the stricter startup framework because the JV entity is new. The policy has not settled, so the safest move is to argue your preferred evaluation lens directly in the offer.
Can I still self-initiate FASt Lane after Refresh 31?
No. Refresh 31 ended self-initiated FASt Lane. An agency must now affirmatively demonstrate a clear, documented need for your specific company before FASt Lane eligibility applies.
What is the two-year business history requirement?
It is GSA's stability screen requiring an applicant to show two years of operating history for a standard MAS award. Companies that cannot meet it apply through Startup Springboard instead, which is designed to evaluate younger entities.
Should I wait for Refresh 33 before applying?
Not necessarily. Refresh 33 may revise some current requirements, but delaying cedes ground while your competitors build agency relationships. Build an application resilient to more than one interpretation and confirm your track before you file.
If you are a startup or JV trying to figure out which track applies and how to argue your evaluation lens, that is exactly the work we do — start at our GSA Schedule services page.