The FAR overhaul moved GSA Schedule rules to GSAR Part 538
FAR Part 38 is gone and Schedule rules now live in GSAR Part 538. What changed, what Refresh 34 adds, and what GSA Schedule contractors should do now.
The short answer: the Revolutionary FAR Overhaul removed FAR Part 38, the part of the government-wide rules that covered Federal Supply Schedules. GSA’s own rules, GSAR Part 538, now carry the Schedule program. For most GSA Schedule (MAS) contractors, day-to-day work stays the same, but the clause numbers and some contract terms are changing, and Refresh 34 is expected to bring the next round in November 2026.
How we got here
April 15, 2025: Executive Order 14275, “Restoring Common Sense to Federal Procurement,” calls for a complete rewrite of the Federal Acquisition Regulation (FAR), keeping mainly what the law requires. The rewrite became known as the Revolutionary FAR Overhaul (RFO).
August 2025: GSA issues a class deviation for FAR Part 38: “FAR part 38, Federal Supply Schedule Contracting, is removed in its entirety.” Schedule guidance moves from FAR Part 38 and Subpart 8.4 to GSAR Part 538.
November 3, 2025: GSA’s Part 38 deviation takes effect.
September 18, 2026: the FAR Council publishes proposed rules that would remove FAR Part 38 permanently and move Schedule ordering procedures into GSA’s rules. GSA publishes a companion proposed rule on September 22. Comments close in mid-October 2026.
November 2026 (expected): MAS Refresh 34, which GSA’s draft says includes a large GSAR Part 538 overhaul.
What changes in GSAR Part 538
GSA’s draft notice for Refresh 34 describes the Part 538 overhaul as moving the Schedule program toward “evergreen contracting.” The main changes in the draft:
No more 20-year limit. The draft removes the 20-year cap on how long a MAS contract can run, tied to the option clause 552.238-116. If that change is final, reaching 20 years would no longer end a contract on its own.
Fewer clauses. The draft deletes 41 GSAR provisions and clauses and eight FAS Schedule clauses.
Five new consolidated clauses: 552.238-190, Federal Supply Schedule Contractor Team Arrangements; 552.238-191, Federal Supply Schedule Contract Requirements; 552.238-192, Federal Supply Schedule Order-level Requirements; 552.238-193, Product Offering and Sales Requirements; and 552.238-194, Sales Criteria.
Ordering rules are on a separate track. The draft does not change GSAR 538.71 ordering procedures; those changes came with Refresh 30 and are going through rulemaking.
These details come from GSA’s draft. The final Refresh 34 can differ, so check the final mass modification before you accept it.
What stays the same
The draft keeps the clauses most contractors deal with every month, including:
552.238-80, Transactional Data and Contract Fee Requirements: monthly TDR reporting and GSA’s fee continue.
552.238-82, Contractor Initiated Modifications: changes you request, such as adding a SIN or labor categories, still go through a modification.
552.516-90, Economic Price Adjustment: price increases still follow your EPA terms.
552.238-77, Pricing and Catalog Data, 552.238-116, Option to Extend the Term, and the records, definitions and order-level materials clauses.
In practice: you still report monthly, request changes through eMod, keep your catalog current and accept GSA’s mass modifications.
What to do now
Make sure your eMod account works and your Authorized Negotiators are current, so you can accept Refresh 34 when it arrives.
Note your contract’s start date and option period. If you were close to the 20-year limit, watch the final Refresh 34 text closely.
Read the final Refresh 34 notice before accepting. Compare it to the draft; GSA has said the final version may change.
Update your internal checklists that cite FAR Part 38 or old clause numbers, so new staff work from the current rules.
Keep your monthly TDR routine going. Nothing in the overhaul pauses it.
Keeping up with GSA’s rule changes is part of what AcqVerity is built for: a step-by-step tool for preparing your own GSA contract changes. We’re opening a small early-access group; join the list at AcqVerity.com.
This guide is general information from public sources, including GSA’s draft Refresh 34 notice, as of October 2026. It is not legal or contracting advice. Your contract terms, GSA and your Contracting Officer decide. AcqVerity Technologies LLC is not affiliated with GSA.