VA Federal Supply Schedule 621 I is the government-wide contract vehicle for temporary clinical staff (physicians, nurses, therapists, technicians) placed in federal healthcare facilities. As of September 2026, awards are nationwide, the ceiling rate is a hard number, and the standing solicitation (RFP-797-FSS-00-0115-R4) accepts offers year-round.
I spent 18 years in federal acquisition as a Contracting Specialist and Contracting Officer at GSA, IRS, DoD, DOI, HHS, FTC, and Energy. Healthcare staffing is one of the few services markets where the VA, not GSA, runs the schedule. For the 20-year performance period, see our earlier post on the VA FSS 20-year extension.
What does VA FSS Schedule 621 I cover?
Schedule 621 I buys temporary professional and allied healthcare personnel to deliver patient care at government locations: medical treatment facilities, VA Medical Centers, clinics, and other federal access points. Placements in private facilities or residences are out of scope. The work is structured as non-personal services under FAR 37.101.
- Special Item Numbers: SIN 621-001 through 621-061 are labor categories, from physician specialties (621-001 to 621-024) to registered nurses (621-025), LPNs (621-038), nurse assistants (621-040), CRNAs (621-053), and nurse practitioners (621-054). SIN 621-099 covers new services. The full list is on GSA eLibrary.
- NAICS: 561320, Temporary Help Services, with a $34 million size standard per the VA 621 I page.
- Maximum order threshold: $1,000,000 per order.
Every labor category must fit a predefined SIN and a healthcare specialty in the BLS Standard Occupational Classification. Name subcategories and levels explicitly (for example, SIN 621-025 Registered Nurse, ER Level I).
What changed on Schedule 621 I between 2025 and 2026?
Six mass modifications and matching solicitation amendments landed between March 2025 and June 2026. The two that change your business model are Mass Mod 22 (nationwide coverage) and Mass Mod 23 (new economic price adjustment clause). The rest update clauses, forms, and the contract term.
| Date | Action | What it does |
|---|---|---|
| Mar 2025 | Mass Mod 20 / Amendment 0006 | Class deviation from FAR subpart 22.8 (Equal Employment Opportunity) |
| Jul 2025 | Mass Mod 21 / Amendment 0007 | New Contractor's Qualifications and Financial Information form; SAM processing clarification; updated FAR clauses |
| Sep 2025 | Mass Mod 22 / Amendment 0008 | Rewrites scope; every contract covers the 48 contiguous states, Alaska, Hawaii, Puerto Rico, DC, and U.S. territories |
| Dec 2025 | Mass Mod 23 / Amendment 0009 | Replaces the old EPA clause with GSAR 552.238-120 (Tailored); new Signature Authority (Aug 2025) and Responsibility Evaluation (Oct 2025) forms |
| Apr 2026 | Mass Mod 24 (Evergreen) / Amendment 0010 | Adds GSAR 552.238-116, FAR 52.217-9, and provision A-FSS-11 (standing solicitation, no closing date) |
| Jun 2026 | Mass Mod 25 | Adds FAR 52.222-90 Addressing DEI Discrimination by Federal Contractors (Deviation) and FAR 52.244-6 (Deviation APR 2026) |
Two housekeeping notes. First, the amendment list on the VA 621 I page does not match the numbering on the SAM.gov solicitation notice, which shows Amendment 0010 posted April 20, 2026. Pull the package from SAM.gov and acknowledge every amendment posted there. Second, the "offers due" date on SAM.gov is a system placeholder. A-FSS-11 states plainly that there is no closing date.
Can an ordering office still pay above the 621 I ceiling rate?
Plan as if it cannot. The order-level exception added by Mass Mod 19 in January 2024 lived in clause I-FSS-969(c) and the old Scope text. Mass Mod 22 replaced that Scope text without it, and Amendment 0009 deleted I-FSS-969. The VA's 621 I page tells contractors to return orders that exceed the not-to-exceed rate.
Some industry summaries still call above-ceiling order pricing permanent. I could not find that language in the current solicitation or the 2025 to 2026 mass mods. With nationwide coverage, that matters:
- Your ceiling must cover your most expensive market. One NTE rate per labor category now spans Manhattan, Anchorage, and rural Puerto Rico.
- Ordering offices evaluate price by location. The Scope text says task order pricing can be significantly below the ceiling. Your ceiling is the maximum, not your quote.
- No all-inclusive rates. Travel and per diem are reimbursed separately when the order authorizes them, and the Industrial Funding Fee does not apply to travel.
If an ordering office tells you otherwise, confirm with your FSS contract specialist before accepting.
How does VA 621 I differ from GSA MAS for healthcare staffing?
GSA delegated medical supplies and services schedules to the VA, so clinical staffing inside federal healthcare facilities belongs on 621 I. GSA MAS SIN 561320 covers temporary administrative and professional staffing. The two programs differ in submission channel, fee, pricing structure, and insurance requirements.
| Factor | VA FSS 621 I | GSA MAS (SIN 561320) |
|---|---|---|
| Managed by | VA National Acquisition Center, Hines, IL | GSA Federal Acquisition Service |
| Scope | Clinical patient care at government facilities | Temporary administrative and professional staffing |
| How you submit | Email to FSSOffersandExtensions@va.gov | eOffer |
| Industrial Funding Fee | 1%, built into the ceiling rate | 0.75% |
| Pricing basis | Fully loaded hourly ceiling (NTE), nationwide | Commercial labor rates by category |
| Price tracking | Tracking customer ratio under GSAR 552.238-81 | See our post on the Price Reductions Clause under MAS Refresh 31 |
| Insurance | $1M per occurrence / $3M aggregate professional liability (VAAR 852.237-70) | Per solicitation and order |
From the Contracting Officer seat, the staffing buys that went sideways were the ones placed on the wrong vehicle. A clinical requirement forced onto an administrative staffing SIN invites a scope challenge and an order the CO has to unwind.
What credentialing does 621 I require for your clinicians?
The Vendor Response Document requires you to certify that every clinician, including subcontractor staff, holds a full and unrestricted license or certification, current BLS or ACLS, required immunizations, and a clean background screen. You also describe your credential verification process in writing.
- Licensure: Full and unrestricted. ECFMG certification or a Fifth Pathway letter alone is treated as restricted and unacceptable.
- Eligibility and life support: U.S. work eligibility, fluent English, and current BLS and/or ACLS.
- Health: Fitness statement, MMR and varicella immunity evidence, and an annual PPD reading, at your cost.
- Screening: Reference and work-history checks, at least a 7-panel drug screen, and sex offender, OFAC, SSN, and ID checks.
- Management plan: Recruitment and retention, a substitution plan for absences, and your malpractice-history verification process.
- Order level: Ordering activities must also comply with VHA Directive 0710 and obtain background clearances.
Does the Service Contract Labor Standards statute apply to 621 I?
Yes, for non-exempt service employees. FAR 52.222-41 applies to 621 I, and the VA posts the current health and welfare fringe rate. Physicians and state-registered RNs generally qualify as exempt learned professionals under 29 CFR 541.301(e)(2). LPNs and similar roles generally do not.
- Exempt professionals: Submit a Professional Compensation Plan under FAR 52.222-46 in Tab 2 of Document 03.
- Covered categories: Nurse assistants, LPNs, medical assistants, and pharmacy technicians typically map to Department of Labor wage determinations. Price at or above the applicable wage and fringe.
- Uncompensated overtime: Attach your policy under FAR 52.237-10 if any category is FLSA-exempt.
As a Contracting Specialist, the services pricing error I flagged most was a blended rate below the wage determination for a covered category. On 621 I, one nationwide ceiling has to clear the highest-wage county you might serve.
How do you get on VA FSS Schedule 621 I?
Download RFP-797-FSS-00-0115-R4 and all amendments from SAM.gov, complete the Vendor Response and Proposed Pricing/CSP workbook, sign the SF-1449 within 10 days of submission, and email the package to FSSOffersandExtensions@va.gov. A contract specialist reviews, negotiates toward most-favored-customer terms, and requests a Final Proposal Revision.
- Register or renew in SAM.gov before you submit.
- Complete Document 02 (Vendor Response) and Document 03 (Proposed Pricing and CSP). CSP data must be current within 60 days of submission.
- Price each labor category as a fully loaded hourly ceiling without the 1% IFF; the workbook adds it. Exclude travel.
- Attach supporting documentation: paid invoices from the last two years, your medical liability certificate, and two years of financial statements or the Contractor's Qualifications and Financial Information form. Do not send tax returns.
- Hold pricing firm for 180 days and sign the SF-1449 no earlier than 10 days before you email the offer.
- Use the subject line format "FSS - Offer - 621 I - Company Name - 1 of #."
If your offer comes back, resubmit the full package; the VA treats it as a new proposal. Across our 70+ GSA contract awards, the most common return triggers are an unsigned amendment and stale CSP dates.
What does it take to keep a 621 I contract after award?
You must report sales and remit the 1% IFF quarterly through the FAS Sales Reporting System, even at $0, file service contract reports by October 31, send insurance certificates annually, and reach $25,000 in reportable sales within 24 months, then $25,000 each year after.
- Quarterly: Sales report and IFF under GSAR 552.238-80, due within 30 days of quarter end.
- Annually: SAM renewal, VETS-4212 by September 30, service contract reporting under FAR 52.204-15 by October 31, and insurance certificates to your contract specialist.
- Minimum sales: Clause I-FSS-639; the VA can cancel under GSAR 552.238-79.
- Price increases: Now governed by GSAR 552.238-120 (Tailored), which references the BLS CPI-U Medical Care Services, Professional Services index for 621 I.
What should you do now?
- Pull the full R4 package and every amendment through 0010 from SAM.gov, not from memory or an old download.
- Re-price every labor category to a single nationwide ceiling that clears your highest-cost market and the applicable wage determinations.
- Stop counting on above-ceiling orders. Build your margin inside the NTE.
- If you already hold 621 I, confirm you signed Mass Mods 22 through 25 and filed your October 31 service contract report.
I hold a FAC-C Level III and a Harvard Master of Liberal Arts, and I have built schedule offers from both sides of the desk. If you want a former Contracting Officer to review your 621 I pricing or package before it goes to Hines, start with our GSA and VA Schedule application support.
Frequently Asked Questions
Is VA Schedule 621 I open for new offers in 2026?
Yes. RFP-797-FSS-00-0115-R4 is a standing solicitation, and provision A-FSS-11 added in April 2026 states there is no closing date. The offers-due date shown on SAM.gov is a system placeholder. Submit whenever your package is complete.
Can I limit my 621 I contract to one state?
No longer. Mass Mod 22 in September 2025 rewrote the scope so every contract covers the 48 contiguous states, Alaska, Hawaii, Puerto Rico, Washington, DC, and U.S. territories. You price one ceiling rate per labor category for that nationwide coverage.
What is the Industrial Funding Fee on VA 621 I?
The VA 621 I pricing workbook applies a 1% Industrial Funding Fee on top of your proposed ceiling rate. Travel and per diem are not subject to the fee.
Do physicians and nurses fall under the Service Contract Labor Standards on 621 I?
Physicians and state-registered RNs generally meet the learned professional exemption in 29 CFR 541.301, so they are covered by a Professional Compensation Plan under FAR 52.222-46 instead. LPNs, nurse assistants, and similar roles generally do not qualify and must be paid at or above the applicable wage determination.
How much malpractice insurance does 621 I require?
VAAR 852.237-70 requires professional liability coverage of at least $1 million per occurrence and $3 million aggregate. You submit the certificate with your offer and send updated certificates to your contract specialist every year.
Should I use GSA MAS or VA 621 I for healthcare staffing?
Use 621 I when the work is clinical patient care at a federal healthcare facility, because GSA delegated medical services schedules to the VA. GSA MAS SIN 561320 is built for temporary administrative and professional staffing.
What is the minimum sales requirement on VA 621 I?
Clause I-FSS-639 requires at least $25,000 in VA-reportable sales during the first 24 months and $25,000 each year after. The VA can cancel a contract that misses those levels under GSAR 552.238-79.