Original Broadcast Date: 3/22/2026
Tom Howder, former deputy commissioner of the Federal Acquisition Service at the General Services Administration, is watching a major shift unfold in federal acquisition—and he makes clear that the changes now underway could have long-lasting impact across government and industry.
At the center of the conversation is GSA’s latest update to the Multiple Award Schedule program, known as “refresh 31.” Howder explains that while some foundational changes were introduced in the previous refresh, this version brings two major elements into focus: transactional data reporting (TDR) and a new American AI clause.
Transactional data reporting has been a long-running effort within GSA, and Howder notes that it has been in pilot form for nearly a decade. Over time, it has expanded from primarily product-based categories into services, though not universally across all special item numbers. That is now changing. With refresh 31, GSA is moving to apply TDR across all schedules, adding previously exempt categories into the framework.
The goal is to move away from the long-standing price reduction clause, which Howder describes as outdated and burdensome. While that clause may have worked decades ago, he explains, it no longer reflects how government buyers operate today. TDR, by contrast, is intended to provide better visibility into pricing and purchasing patterns, helping the government make more informed decisions.
However, the shift is not without challenges. Howder points out that TDR is easier to implement for straightforward, non-configurable products. When it comes to more complex offerings—like configurable products or services—the process becomes much more difficult. Comparing pricing across different configurations or service variations is not always straightforward, and that has been a persistent issue flagged by oversight bodies like the GSA Inspector General.
Even so, Howder frames this moment as a turning point. GSA, he suggests, is effectively making a “fish or cut bait” decision—committing fully to TDR as the future of the program. If successful, the move could help position the entire Multiple Award Schedule program as “best in class,” a designation that carries increasing importance as agencies are encouraged to prioritize those contracts.
Beyond TDR, Howder highlights the introduction of a new governmentwide AI clause as another major development. The intent behind the clause is clear: reduce supply chain risk, protect government data, and establish consistent standards for the use of artificial intelligence in federal procurement. He describes these goals as both important and necessary.
At the same time, he acknowledges significant concern within the contractor community. The clause is extensive—spanning multiple pages of detailed requirements—and vendors are being asked to comply within a relatively short timeframe. For many companies, that creates uncertainty about how to meet the requirements, even with the best intentions.
One of the more complex aspects of the clause is its scope. Vendors are not only responsible for their own use of AI, but also for the actions of subcontractors and even upstream suppliers. Howder notes that this creates a difficult dynamic, especially when those suppliers include large technology companies over which contractors may have little influence. Despite that lack of leverage, contractors would still be held accountable for compliance.
He also points out that while the clause is designed with strong intent, the speed at which it is being introduced may be contributing to industry concern. With a relatively short comment period and tight deadlines for implementation, companies are working quickly to understand and
Looking more broadly, Howder places these changes within the context of a larger acquisition transformation. Efforts like the FAR overhaul and the “OneGov” initiative are aimed at reducing bureaucracy, removing outdated requirements, and giving contracting officers more flexibility. Refresh 31, he explains, helps set the stage for those changes by simplifying parts of the acquisition framework and aligning it with modern practices.
However, he emphasizes that real impact will depend on execution—particularly at the contracting officer level. The new flexibilities will only matter if they are actually used. That, he says, will require significant training and reinforcement across agencies. Without it, there is a risk that contracting professionals will fall back on familiar habits, limiting the benefits of reform.
As for what comes next, Howder outlines two possible paths. If feedback from industry is extensive and raises significant concerns, GSA may pause and adjust its approach before moving forward. Alternatively, the agency may proceed quickly with implementation and refine the details later. At this stage, it is not yet clear which path GSA will take.
For agencies, Howder suggests a wait-and-see approach may make sense, given the potential benefits of the changes. For vendors, however, engagement is critical. Providing feedback during the comment process is an important opportunity to shape the final outcome.
Ultimately, Howder sees these developments as part of a broader effort to modernize federal acquisition. The direction is clear: more data-driven decision-making, greater standardization, and stronger safeguards around emerging technologies like AI. The challenge now is ensuring that those goals are achieved in a way that works for both government and industry.