March 25, 2026

Alan Thomas, founder of Alpha Tango Strategies and former commissioner of the Federal Acquisition Service at GSA, is raising important questions about proposed changes to the Multiple Award Schedule (MAS) program. In a recent Fed Gov Today interview, Thomas walks through key elements of what’s known as “Refresh 31” and a separate, closely watched AI clause that could reshape how companies engage with the federal marketplace.

Thomas explains that one of the most significant changes in Refresh 31 is the expansion of Transactional Data Reporting (TDR). Previously limited to certain products and categories, TDR is now set to apply across the entire schedule, including services and highly configurable products. While this move aims to give the government better data for pricing and negotiations, Thomas notes it introduces new layers of complexity for vendors.

For example, he highlights the challenge of reporting on fixed-price services contracts. Vendors may struggle to determine what data to submit—whether it’s total contract value, monthly payments, or more granular details. That ambiguity, he says, makes it harder not only for industry to comply, but also for government buyers to effectively use the data in negotiations.

Despite these concerns, Thomas emphasizes that TDR replaces the longstanding Price Reduction Clause, which many in industry view as burdensome. In that sense, the shift to TDR represents a positive step. However, he cautions against what he calls the “Christmas tree effect,” where additional reporting requirements gradually accumulate over time. While the current framework includes a defined set of mandatory and optional data elements, Thomas notes the risk that stakeholders could continue adding more, potentially creating new burdens that outweigh the original benefits.

He underscores that both GSA and industry share responsibility in preventing that outcome. GSA, he says, generally acts as a balanced intermediary, while industry and trade associations must remain engaged and vocal to ensure the reporting requirements remain practical.

The second major topic Thomas addresses is the proposed AI clause, which has already sparked significant reaction. He observes that GSA has decided to separate the clause from Refresh 31 and extend the comment period, signaling that officials anticipate substantial industry feedback.

Thomas describes the AI provision as a “maximalist” approach, particularly in areas like intellectual property, data rights, and supply chain requirements. While he acknowledges the government’s intentions—especially around supply chain security—he expresses concern that the clause could create unnecessary burdens and even discourage companies from entering the federal market.

He points out that the United States benefits from a strong ecosystem of innovators who attract talent and investment to build cutting-edge solutions. Policies that complicate participation in the federal space, he warns, risk undermining that advantage. In his view, the government should avoid actions that make it harder to leverage those innovations.

Looking ahead, Thomas expects Refresh 31 to move forward largely as planned, with ongoing collaboration between GSA and industry to clarify TDR implementation. The AI clause, however, remains an open negotiation. He anticipates industry will push back—likely through trade associations—and that GSA will ultimately revise the language.

Throughout the conversation, Thomas frames these changes within broader modernization efforts, including FAR overhaul initiatives. While he sees alignment in some areas, he notes the AI clause appears less consistent with GSA’s recent efforts to mirror commercial practices.

Ultimately, Thomas presents a balanced perspective: progress is being made, but careful execution and continued dialogue will be critical to ensuring these changes support both government efficiency and a healthy, innovative contractor base.