GSA MAS Refresh 11 - Revised Note on COVID-19 Clause

Explore the notable changes in GSA MAS Refresh 11, including the revised note on COVID-19 safety protocols and the deletion of SIN 541513.


The world of government procurement constantly evolves to keep pace with regulations, court rulings, and market dynamics. A recent embodiment of these changes can be seen in the General Services Administration's (GSA) issuance of Refresh 11 of the GSA Multiple Award Schedule (MAS). Coming soon after Refresh 10, this update carries two important modifications.

Understanding the Changes

  • Deletion of SIN 541513, Smart Buildings Systems Integration
  • Revised Note Regarding FAR 52.223-99, COVID-19 Safety Protocols for Federal Contractors

Deletion of SIN 541513: A Closer Look

The first significant change in Refresh 11 aligns with actions taken in the preceding Refresh 10. Here, SIN 541513 was absorbed into SIN 561210SB. Though previously concentrated on smart building systems integration, the functionalities and offerings of SIN 541513 are now housed in SIN 561210SB, Smart Buildings Systems Integrator. The primary intent behind this consolidation is to streamline the GSA Schedule's deliverables relating to smart building services.

Impact of Revised FAR 52.223-99: What It Means

At the initial stages, the Government declared its lack of intention to enforce the FAR clause detailing COVID-19 safety protocols, inclusive of vaccine requirements. The clause was to be consequential only in states or regions lacking a court order barring its application.

However, an Arizona court ruling introduced a fresh development, leading to further conditions in Refresh 11. The adjusted clause now specifies that FAR 52.223-99 will self-delete in any contract or order, issued post February 10, 2022, if:

  1. A party to the contract is an entity with its headquarters in Arizona, or if the State of Arizona or any of its agencies are involved.
  2. The work relegated under the contract primarily occurs in Arizona.

Such an amendment corresponds to the need for compliance with Arizona's specific legal ruling and signifies that the clause surrounding COVID-19 safety protocols will not apply if the majority of the contract’s work is performed in the state, or if the agency involved is based in Arizona.

Importance and Implication of Refresh 11

The changes demonstrated in Refresh 11 are indicative of GSA’s continuous efforts to keep the MAS program in tune with present regulations, court orders, and market dynamics. The removal of SIN 541513 aims to make the contract vehicle more simple and straightforward. Concurrently, the updated note on COVID-19 safety protocols is a direct response to legal adjustments influencing federal contracting.

Former GSA Schedule Reviewers are at your service, offering the most reliable GSA Schedule Consulting services in light of these changes.


Navigating the changing waters of government procurement can be tricky. However, updates like the GSA MAS Refresh 11 highlight the importance of staying abreast with the changes in regulations and court rulings. Remain vigilant, stay informed, and when in doubt, reach out to seasoned professionals for the best advice on successfully managing your GSA Schedule.

Pedro has extensive background as a Contracting Officer and Contract Specialist, has worked across seven federal agencies, managing contracts totaling over $1 billion in the professional and tech sectors. His notable tenure includes serving with the DoD/DARPA during the inception of their robotics program. Additionally, he played a pivotal role in initiating the Cyber Special Item Number (SIN) within the GSA's IT Schedule 70 as a Team Lead. After graduating from Harvard, he started Blackfyre to help you win your next contract.

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