1. What are OLMs?
An OLM is a product, service, or solution that is not available under the Contractor's FSS contract, but is needed for performance of the order. An OLM can be obtained from another FSS contract, a mandatory or non-mandatory Government source, or a commercial source.
Order activities must follow the order of priority of sources before obtaining an OLM from a commercial source (see FAR 8.105 (GSA Class Deviation RFO-2025-FSS-GSAR 538)).
2. What qualifies as an Order-Level Material (OLM)?
A product, service, or solution qualifies as an OLM if it meets the following:
- Direct Support: It is required for the direct support of an order or BPA.
- Not Awarded: It is not awarded on your FSS contract.
Reminders:
- ODC SINs (e.g., 541810ODC) and ANCILLARY SINs are not OLMs.
- OLMs do not include costs that are separately addressed elsewhere in your FSS contract (e.g., Travel).
- If you are a part of or will enter into a FSS Contractor Team Arrangement (CTA), any products, services, or solutions provided by other CTA participants in support of the specific order would not be considered OLMs for the portion of work you are performing.
- Not the Primary Purpose: It does not represent the primary purpose of the order or, if applicable, your BPA that the order is being placed against.
- Compliance: It complies with all FSS contracts terms and conditions. For example, products that are prohibited by applicable law or Executive Order are not eligible for inclusion on an FSS contract.
3. What are some common examples of OLMs?
Common examples include:
- Incidentals.
- Consumables.
- Material handling costs.
- Customized services, such as customized training.
- Specialized services, such as specialized repair work.
- Shipping / Freight costs applicable to FOB Origin products.
- Installation/Site preparation, such as electrical work, plumbing, or painting.
- Specialized materials and supplies, such as specialized cabling, insulation, or tools.
3. What are Non-FSS items?
Non-FSS items were previously referred to as ‘open market items” under FAR 8.402(f).
Non-FSS items are products, services, and solutions that are:
- Outside the authority and scope of the FSS program (e.g., not bound by the terms and conditions of the FSS program);
- Neither FSS items or OLMs.
- Though OLMs may include items obtained outside of FSS, they must comply with all MAS terms and conditions (e.g., commerciality and TAA compliance).
- Items that have their own pricing, period of performance, contract clauses, etc.
- Items that are procured from you, the vendor, on a standalone basis via a separate award, not in your capacity as a MAS contractor.
4. How can ordering activities obtain Non-FSS items?
To procure Non-FSS items, the ordering activity-
- Must conduct a separate procurement for these Non-FSS items.
- The award must be made to you, the vendor, on a standalone basis, not in your capacity as a MAS contractor. There should be no reference to your MAS contract.
- Is responsible for complying with all applicable acquisition regulations, and
- Should leverage available acquisition flexibilities to procure Non-FSS items.
5. Can I combine Non-FSS items and FSS items into one invoice?
You, as the vendor, need to coordinate with the ordering activity prior to submitting a consolidated invoice that includes non-FSS items and FSS items. Ordering agencies may have their own requirements necessary to ensure the invoice properly identifies the separate procurements.
6. Can an OLM item be added at the BPA level?
No, at this time, an OLM item can be added under a BPA Call / order but not on the BPA itself. Pursuant to GSAR 538.71 (GSA CD RFO-2025-FSS-GSAR 538), an OLM is an item that is not known at the MAS contract or FSS BPA level and cannot be added under the base level BPA.
7. Can an OLM be a non-commercial item?
No, an OLM cannot be a non-commercial item when acquired through the FSS program, which is exclusively for acquiring commercial products and commercial services. Any OLM added to an order must satisfy the definition of a "commercial product" or "commercial service" as outlined in FAR 2.101. It is the OCO's responsibility to ensure that each OLM offered meets the definition of a commercial item.