Can OLMs be used on a fixed-price order
Yes, OLMs can be used to support any type of authorized order, whether it's a fixed-price order, a time and materials order, or a labor-hour order. The type of order doesn't restrict the use of OLMs.
Does the 33.33% limitation still apply to OLMs?
No, the 33.33% no longer applies to OLMs under the new FSS Order procedures. However, the product or service must not be the primary purpose of the task or delivery order. OLMs are intended to support the main objective of the order or total solution. When determining what percentage of the OLM is too much of an order, you can utilize any of these thresholds:
- It is not the primary driver of the technical evaluation or performance metrics, and
- It is not the main deliverable in the PWS/SOO.
The government will not issue an order solely for the OLM product or service if it is the primary purpose of the order GSAR 538.7104-2(a) (GSA Class Deviation RFO-2025 FSS-GSAR 538).
Is the OLM “primary purpose” rule equivalent to a strict dollar-value threshold (e.g., less than 50%)?
No. While dollar value is an important indicator, the primary purpose determination is not a strict percentage test. Ordering activity contracting officers are responsible for assessing the overall nature of the requirement, and cost alone is not determinative.
Can OLMs be procured under cooperative purchasing orders?
Yes, OLMs are permitted when used in conjunction with a Cooperative Purchasing-eligible SINs.
Can the OLM SIN be used to obligate funds for later use?
No. Use of the OLM SIN is subject to the Bona Fide Needs Rule. Funds must support a legitimate need of the fiscal year in which they are obligated.
What subcategories under MAS are OLMs currently allowed?
The OLM SIN is now open to all MAS contractors as of MAS Refresh 31 (APR 2026). A good practice for Ordering Contracting Officers (OCOs) is to verify whether the quoter has the OLM SIN awarded on their contract.