What are the requirements for OLMs?
OLMs must meet the following requirements:
- Primary Purpose: OLMs must not be the primary purpose of the task or delivery order. They are intended to support the main objective of the order.
- OLM SIN: FSS Contractors must have the OLM SIN awarded on their FSS contract.
- Identification of OLMs: OLMs must be clearly identified on the order. on the order.
- Sales Reporting & Compliance: OLMs under FSS are subject to sales reporting and require compliance with all FSS contract terms and conditions (e.g., TAA, Security Prohibitions and Exclusions, Cybersecurity Supply Chain Risk Management (CSCRM) requirements).
- Commercial Item/Service: OLMs must satisfy the definition of a "commercial product" or "commercial service" as outlined in FAR 2.101.
Do OLMs have to be clearly identified on a GSA order?
Yes, it's essential that OLMs are clearly identified as OLMs on any FSS order. This is because OLMs should support the main purpose of the task or delivery order, not be the main purpose themselves. Separating out the OLM also aids the ordering activity in determining the OLM price fair and reasonable. Also, the FSS Contractor selling the OLMs must have the OLM SIN listed on their FSS contract.
Who determines the fair and reasonable price of an OLM?
The ordering contracting officer (OCO) is responsible for ensuring that all OLM prices at the order level are fair and reasonable. This means the OCO needs to perform his/her due diligence to confirm that the prices being charged for the OLMs are justifiable and in line with market rates
Are OLMs subject to Fair and Reasonable Price Determinations?
Yes, All OLMs are subject to fair and reasonable price determinations. The agency must ensure that the prices charged for the OLMs are justified.
Can a FSS contractor add a “fee” or “handling fee” to OLMs?
Yes, FSS contractors can add a fee for indirect costs if the OCO reviews and approves them. Approved fees must:
- Include the IFF; and
- Be listed as a separate line item on the order.
The OCO must determine that all fees approved for payment are fair and reasonable.
Are vendors required to provide price analysis documentation when a vendor purchases from another MAS contract to supplement their quote?
No, unless requested by the Ordering Activity as part of their RFQ
When can OLM be added to a BPA order?
OLMs can be incorporated into orders placed against existing FSS BPAs only if:
- The underlying MAS contract includes the OLM SIN;
- The OLMs are within the scope of the BPA and support work performed under other awarded SINs; and
- Utilizing OLM flexibility does not alter the BPA's primary purpose or scope.
Since OLMs are by definition unknown at the time of BPA establishment, OCOs must determine whether the OLM SIN and the specific products or services to be procured under it fall within the scope of the underlying FSS BPA. OLMs may only be acquired in direct support of work performed under existing BPA SINs.
Do I need to inform an FSS contractor that they can propose OLMs in response to my RFQ?
Yes, it is a good practice for you (OCO) to inform FSS Contractors to utilize OLM as part of their quoted solution. Providing for OLM will enhance competition. Note. FAR clause 52.208-90, Government Supply Sources (Nov 2025) (Deviation), is included in most FSS contracts, this clause authorizes FSS Contractors to act on the Government’s behalf to utilize Government supply sources for products or services essential to fulfilling the order.