Why You Need to Respond to GSA’s Deregulation Proposals
If you’ve been following our recent updates, you may recall a previous post where we highlighted the GSA’s open invitation for public comment on proposed deregulations affecting the Multiple Award Schedule (MAS) program. This rare opportunity to shape the future of federal acquisition is already yielding significant implications, most notably, the potential rescission of FAR 538.272 and clause 552.238-81, better known as the Price Reductions Clause (PRC). For those of us working daily in this space supporting clients through GSA offers, modifications, and compliance audits, this proposed change will have a significant impact on the industry.
The Price Reductions Clause is a Compliance Relic
At its core, the Price Reductions Clause (PRC) was originally designed to ensure that the Government would never pay more than a contractor’s “Most Favored Customer” (MFC). While that concept may have been appropriate decades ago, it no longer aligns with the realities of modern government procurement.
Today, pricing under the MAS serves as a ceiling—not a floor. Agencies rely on competition at the order level, issuing RFQs to drive prices below awarded rates. Vendors routinely discount their MAS prices in response to this order-level competition, especially since GSA contracts include a “Maximum Contract Value” that limits the rates they can negotiate.
Moreover, the advent of Transactional Data Reporting (TDR) has rendered traditional discount tracking less relevant. TDR provides real-time visibility into what the government actually pays for goods and services, enabling transparency that was previously unachievable with static MAS pricing alone.
Despite this evolution, the PRC continued to require contractors to track commercial discounting practices, report changes, and remain vigilant to avoid non-compliance—even for limited-time promotions to private-sector clients.
The result? A burdensome compliance regime that imposed significant legal and administrative costs, especially on small and emerging businesses. Rather than improving pricing outcomes, the PRC introduced audit risk, legal exposure, and overhead—without delivering measurable benefits to the Government or taxpayers. The Proposed Fix: Eliminate the PRC, Expand TDR, and Modernize MAS.
K&G’s proposal calls for:
Rescinding FAR 538.272 and clause 552.238-81
Expanding Transactional Data Reporting across all applicable SINs
Eliminating pre-award price negotiations in favor of ceiling pricing and order-level discounts
Re-aligning GSA Schedule policies with how the government actually buys today
This is more than a technical update—it’s a philosophical shift away from outdated regulatory constraints and toward a model that prioritizes data-driven transparency, flexibility, and real competition.
Why This Matters to You
K&G spports hundreds of contractors across all stages of the MAS lifecycle, we see firsthand how the current system discourages innovation, deters participation, and hurts the very agencies the MAS program is designed to help.
If you are:
A current GSA Schedule holder bogged down by PRC reporting
A prospective contractor turned away by MAS complexity
A compliance officer worried about pricing triggers
A small business struggling with the burden of documentation
This is your chance to influence the rules.
How to Get Involved
GSA is currently accepting public comments on this proposed rescission and related deregulation efforts. Submitting a well-reasoned comment helps create a record of industry support for modernizing the MAS program, provide data and case studies on the burdens you’ve experienced and nsures GSA hears from stakeholders beyond trade associations. We encourage everyone impacted—contractors, consultants, counsel, and buyers—to take 30 minutes to draft a thoughtful comment. Or better yet, reach out—we’re happy to help shape your message.
Federal acquisition is often seen as immovable—but moments like this prove otherwise. GSA’s willingness to consider bold reform deserves industry engagement in return. Don’t let outdated rules define how you do business with the government.
This is your opportunity to help build a better MAS program. Let’s not waste it.
