GSA Multiple Award Schedule (MAS) Pricing: What You Need to Know

At a Glance:

• Main Takeaway: GSA MAS contracts utilize two methods to determine contract prices, each with specific disclosure and compliance requirements.
• Business Impact: GSA ensures MAS contract pricing is fair and reasonable by requesting discounts, reviewing support for proposed pricing, and performing market research and analysis.
• Next Steps: Aprio’s Government Contracting team can help determine the best pricing method for your GSA contract to minimize compliance risks and maximize your success under the contract. Schedule a consultation today.

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BREAKING NEWS: GSA recently announced a major expansion of Transactional Data Reporting (TDR). GSA is ending the TDR pilot period as of Solicitation Refresh 27 (expected late June 2025), making TDR a permanent and mandatory program for covered Special Item Numbers (SINs). GSA is also making TDR mandatory for 62 additional SINs in the refresh. Any contractor with a covered SIN will be required to opt-in to TDR by September 30, 2025. GSA will make TDR participation mandatory for ALL SINs at some point in fiscal year 2026. Once that happens, Commercial Sales Practices (CSP) disclosures and the Price Reductions Clause (PRC) will no longer apply to any MAS contract!

The Full Story:

A GSA Multiple Award Schedule (MAS) contract provides contractors direct access to the U.S. government’s extensive purchasing power. GSA’s primary focus for MAS contracts is obtaining pricing that is advantageous to government purchasers. Because the government has such a high purchasing volume, GSA expects to receive some of the best pricing and value on MAS contracts.

MAS Contract Pricing: How Does It Work?

GSA utilizes two methods to determine MAS contract pricing:

1. Commercial Sales Practices Method

Commercial Sales Practices (CSP) list a contractor’s customers and each customer’s associated pricing for a recent 12-month period. This includes all classes of commercial customers, whether commercial end-users, prime contractors, state and local governments, or resellers. The CSP is also used to determine a Most Favored Customer (MFC), the customer who receives the contractor’s best pricing. GSA will use this information to evaluate the pricing proposed to GSA by the contractor. Contractors can use the CSP method for any offer. However, it is mandatory on offers that do not include a Transactional Data Reporting (TDR)-covered Special Item Number (SIN).

• An important note: When employing the CSP method to determine pricing, the Price Reductions Clause (PRC) will apply. This clause requires the contractor and GSA to agree upon a customer or group of customers known as the Basis of Award (BOA) customer. This can be the MFC or a different customer. After the BOA is determined, GSA and the contractor must also agree on a contractual relationship between the GSA and BOA discounts. If the discount relationship changes in any way, it will trigger the PRC. If the clause is triggered, contractors have 15 days to notify the GSA Contracting Officer and reduce GSA’s pricing accordingly.

2. Transactional Data Reporting Method

Transactional Data Reporting (TDR) is a newer pricing method that eliminates the requirement for contractors to submit CSP disclosures and comply with the PRC. Because TDR is still a pilot program, participation is only available on contracts with certain SINs. TDR contractors have more freedom to propose pricing without submitting commercial rate support or pricing disclosures. In exchange, contractors must provide detailed prices paid data to GSA monthly, which may be used to negotiate MAS ceiling rates. Even though the contract is not subject to the PRC, contractors may be asked to decrease their pricing based on competitors’ rates for similar products and services.

How Does GSA Establish Fair and Reasonable Pricing?

Whether you select the CSP or TDR methodology, GSA contract pricing involves negotiating ceiling rates and potential discounts within the framework of the MAS program. GSA’s goal is to ensure prices are fair and reasonable. The process of determining pricing includes: 

• Negotiating Discounts – GSA prefers contractors to offer three types of discounts, including a basic discount from commercial or market prices, quantity/volume discounts, and prompt payment discounts. GSA also encourages competition at the MAS order level, increasing the likelihood of further discounting. TDR participants must report discounted pricing offered at the order level, which may be used later to renegotiate the MAS ceiling rate.
• Performing Market Research and Analysis – GSA uses market research and analysis tools such as the GSA Advantage! online marketplace for products and the Contract Awarded Labor Category (CALC) tool for labor categories offered on GSA contracts. GSA also examines prices paid data, current commercial prices of the contractor and its competitors, and industry trends.
• Reviewing Rate Support – GSA often requires contractors to submit documents to support their proposed pricing, such as copies of invoices that show prices paid.

The Bottom Line

There is a lot of information to digest about GSA MAS contract pricing and how it is awarded. Choosing the best pricing method for your business and understanding how GSA evaluates rates are critical to creating a profitable MAS strategy. Contractors can obtain GSA MAS contracts using either CSPs or TDR, and each method has its own set of requirements. Whichever method you choose, pricing will be evaluated by GSA using different techniques to ensure GSA receives what it considers fair and reasonable pricing.

Knowing the ins and outs of GSA pricing is not easy, but Aprio’s Government Contracting professionals have the specialized knowledge and experience to help you set your company up for success. Contact our team today.

Related Resources:

• Breaking Down the GSA Multiple Award Schedule (MAS)
• Essential Insights for Navigating GSA Schedule Offers
• GSA Multiple Award Schedule 101
• Top Five Failures in GSA Office of Inspector General (OIG) Audits #1, The Price Reduction Clause
• The Ten Commandments of GSA Schedule Compliance