Can agencies establish additional business practices for OLMs?
Yes, agencies have the flexibility to establish additional business practices for OLMs (see FAR 1.201)). Any such business practices must not conflict with the FSS contract, depending on the specific needs of the order.
What industry standards apply to OLM?
Ordering Contracting Officers (OCOs) determine the standards for OLMs and acceptance for purposes of award (e.g., ANSI/BIFMA for furniture).
Do OLM's have to comply with Supply Chain Risk requirements?
Yes, all OLMs added to an order must adhere to the same terms and conditions as the base FSS contract, including compliance with: FAR 52.240-91 Security Prohibitions and Exclusions (Nov 2025) (Deviation). FAR 52.225-5 – Trade Agreements Act (TAA). Other applicable cyber or national security directives (e.g., EO 14028, CISA directives). The Ordering Contracting Officer is responsible for ensuring compliance with such requirements prior to adding OLMs to an order.
Do Schedule contract-level terms and conditions apply to OLMs?
Yes, FSS contract terms and conditions apply to OLMs with the following exceptions*. OLMs are exempt from the following MAS clauses:
- 552.238-120, Economic Price Adjustment.
- 552.238-77, Submission and Distribution of Authorized FSS Schedule Pricelists
- 552.238-88, GSA Advantage.
- 552.238-81, Price Reductions.
*GSA is in the midst of reviewing and updating FSS terms and conditions in support of the Revolutionary FAR Overhaul. As a result, the citations provided are current as of the date of this document and are subject to change.
Does Transactional Data Reporting (TDR) apply to OLMs?
Yes, TDR requirements apply to OLM pursuant to GSAR 552.238-80 (i.e., all required TDR data elements must be reported for the OLM SIN, just as with any other awarded SIN). Except if the OLM is provided by another MAS contractor then that company would remit the transactional data.
Is the ordering activity responsible for verifying the FSS contractor's authority to sell/provide the items quoted under OLM SIN?
Yes, OLMs are established at the order level. Any required verification of the FSS Contractor's authority to sell the item is the responsibility of the OCO.
Are MAS contractors required to accept orders from other MAS contractors just as they are required to accept orders from executive agencies?
No, contractors are not required to accept orders from other contractors see Clause 552.238-114(c)