Federal agencies relying on GSA Schedule pricing may face increased risk of overpayment, prompting potential new expectations for contractors to justify pricing.
As part of the GSA Office of Inspector General’s Fiscal Year 2024 Audit Plan, an audit was conducted to analyze price variability in the Multiple Award Schedule (MAS) Program and determine potential causes. Report Number A240052/Q/6/P26001, titled Federal Agencies Are at Risk of Overpaying for Products in the Multiple Award Schedule Program Due to Significant Price Variability, was issued on February 12, 2026.
Historically, contractors may have relied exclusively on their GSA schedule pricing without providing additional support. Based on the OIG’s findings, contractors should now expect requests for justification or backup documentation for GSA pricing, even on awards made under the MAS program. This requirement can be particularly challenging given GSA’s existing “most favored customer” discount obligations.
Contractors should therefore track proposed pricing for supplies and services not only for federal customers through the MAS, but also for other government contracts and commercial sales. Maintaining consistent and supportable pricing across markets will be increasingly important.
BACKGROUND
The audit sought to determine whether GSA’s Federal Acquisition Service (FAS) is adequately addressing price variability within the MAS program to ensure schedule pricing results in the lowest overall cost alternative to meet government needs, consistent with federal laws, regulations, and internal guidance.
The audit found that federal agencies relying on schedule pricing face a risk of overpaying for products due to significant price variability. This variability was attributed in part to contracting officers not consistently evaluating proposed pricing and to certain FAS policies and procedures related to MAS pricing being unused or ineffective.
Under FAR 8.404(d), ordering activities are not required to make a separate determination of fair and reasonable pricing. By placing an order under a schedule contract using the procedures in FAR 8.405, the ordering activity is considered to have concluded that the order represents best value, as defined in FAR 2.101, and results in the lowest overall cost alternative considering price, features, and administrative costs.
Similarly, the Revolutionary FAR Overhaul subpart 8.401(b), and GSAR 538.7102 2(d)(2), state that ordering activities are not required to make a fair and reasonable price determination for Federal Supply Schedule products, services, or solutions at the order or BPA level because FSS contract pricing has already been determined fair and reasonable.
This framework was designed to encourage agencies to use the MAS program. However, the OIG audit found that MAS awarded pricing is often unsupported. As a result, agencies relying solely on schedule pricing determinations may face increased risk of overpaying.
The audit includes several recommendations aimed primarily at improving MAS program processes, policies, and procedures. Notably, the OIG recommended that the FAS Commissioner advise federal customer agencies to conduct their own independent price evaluations due to the risks created by significant price variability.
🚨 New GSA OIG Audit Raises Concerns About MAS Pricing Variability
Next Steps
To reduce the risk of delays or challenges during award, Gov Contract Pros recommends that contractors proactively prepare fair and reasonable pricing documentation to support their proposed prices, even for MAS orders.
GCP will continue to monitor developments related to MAS pricing oversight and guidance.
For additional information, please contact Christopher Cox at christopher.cox@govcontractpros.com.
