GSA Schedule Holder Policy Changes Will End Pandemic-Era Pricing Restrictions In September 2025
- Ken Larson
- 2 minutes ago
- 2 min read
“WASHINGTON TECHNOLOGY “By Amelia Bock
“September brings an end to pandemic-era pricing restrictions and with more flexibility for schedule holders. COVID-era contract pricing will change, along with some updated requirements to the Multiple Award Schedule program. That also spells good news for contractors.”
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“On March 17, 2022, the General Services Administration issued Acquisition Letter MV-22-02, to provide a moratorium on rules established in Economic Price Adjustment clauses 552.216-70, I-FSS-969 and 52.216-71. Those rules were created to maintain reasonable and competitive market conditions.
MV-22-02 temporarily allowed contract holders to increase pricing due to supply chain shortages, inflation and price volatility created during the pandemic. It also removed a requirement for additional approvals above contracting officer level.
The moratorium is now expected to end on Sept. 30. A new clause has been added to EPA, 552.238-120, outlining procedures for price adjustments across a contract period. The ability to increase prices without adhering to strict limitations was released temporarily; it will remain a permanent rule for price hikes.
Easing on price restrictions begins with change order 187 GSAR Case 2020-G510, which was released Sept. 4, 2024, to bridge the gap until the solicitation is updated in September 2025, with updates to Economic Price Adjustment rules. These changes are intended to streamline procurement processes, provide more flexibility to contractors and “align with commercial standards and practices.”
The change order removes several restrictions to increasing prices — for example, the number of price increases per year, the ceiling on percentage increases and the minimum time between each increase.
Previously, EPA allowed prices to increase no sooner than 12 months after part numbers had been approved on a contract. Price increases were limited to no more than three times and an aggregate of no more than 10 percent per year. Now the contracting officer assigned to the GSA contract has discretion over those numbers.
This is great news for GSA contract holders. With fewer restrictions, prices can fluctuate with market conditions. These changes will also allow for more competition and better alignment with commercial practices.
Despite getting some relief on price restrictions, one important place where the burden on contractors remains unchanged, or even higher, is “price reasonableness.” Contracting officers will request price justification based on the “4P” analysis — product, price, place and promotion.
This justification is made evident in the form of paid invoices, publicly posted commercial pricing, comparable products already approved, and letters explaining the reasoning for increase. Reasons for an increase can include inflation, changes in the market and changes in products.
This means that the time required to obtain and review price justification documents may result in extended approval times.
It’s important to understand the implications of these changes not only to have a firm handle on how your organization can adjust prices, but how that can add time to the approval process.”
ABOUT THE AUTHOR:
Amelia Bock is a federal contract specialist for immixGroup, the public sector business of Arrow Electronics.
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