GSA Shuffles Rules for Easier Government Shopping Lists
Published Date: 9/22/2026
Proposed Rule
Summary
The General Services Administration (GSA) is updating its rules to move Federal Supply Schedule ordering procedures from one set of rules to another, making things clearer and easier to follow. This change affects anyone who orders supplies through the Federal Supply Schedule and aims to streamline the process without changing costs. Comments on this proposal are open until October 22, 2026, so get involved if you have thoughts!
Analyzed Economic Effects
7 provisions identified: 4 benefits, 1 costs, 2 mixed.
One‑time Familiarization Training Costs
GSA estimates one‑time familiarization and training costs linked to this change: $1,390,830 for ordering activities, $567,775 for existing and prospective FSS contractors, and $33,115 to update FSS program resources. These are non‑recurring costs the Government says will be offset by qualitative benefits.
Streamlined FSS Rules to Boost Competition
GSA will move Federal Supply Schedule ordering procedures from FAR part 8 into GSAR part 538 and reorganize them, reducing the text from over 10,000 words to approximately 2,600 words. GSA expects this to increase competition, reduce administrative time, and encourage more businesses to pursue FSS contracts.
Less Order‑Level Paperwork for Buyers
Under the new GSAR subpart, ordering activities are not required to determine contractor responsibility at the order level or make a fair and reasonable price determination at the order level for items priced on the contractor's FSS contract. This should reduce steps ordering officials must perform when placing FSS orders.
Clearer Order‑Level Material (OLM) Rules
The rule relocates and clarifies Order‑Level Materials (OLM) requirements: OLMs must not be the primary purpose of an order, must be identified as OLMs, the underlying FSS contract must include the OLM SIN, and a fair and reasonable price determination must be made for each OLM at the order or BPA level (with specific exceptions for OLMs acquired from other FSS contracts).
More Flexible Ordering Options and Payment
The proposal allows ordering activities to place orders orally (in certain procedures), to use the Governmentwide commercial purchase card as payment or to place orders regardless of dollar amount (subject to applicable limits), and to set aside BPAs or orders for small businesses. These flexibilities aim to speed and simplify purchases.
Sole‑Source Justifications and Public Posting
When an order or BPA is awarded on a sole‑source basis, written justifications must be prepared and made publicly available: generally within 14 days after award (30 days for certain urgent justifications) and posted at the Government‑wide Point of Entry and the ordering activity's website for at least 30 days, after appropriate screening and redactions.
BPA Content, Duration, and Annual Review Rules
The GSAR subpart sets minimum BPA content (scope, ordering period, invoicing/delivery terms, authorized customers), allows BPAs to extend beyond a contract term if options cover the period, and requires annual reviews (or before exercising options) to confirm best value, quantities, pricing, contract status, and OLM necessity.
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Key Dates
Department and Agencies
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