GSA OLM Explained: 2026 Rules for MAS Contractors

What Are GSA Order Level Materials (OLM)?

Federal agencies often need products or services that were not identified at the time a Schedule contract was awarded. This is where Order Level Materials come in.

You’ve got a contract to provide consulting services but during the project, your client needs some specialized software. Or maybe training materials. Or even equipment that directly supports your main service.

This is where GSA Order-Level Materials (OLM) applies.

Order Level Materials, or OLM, are products and services that federal agencies can buy alongside your main contract. They’re extras that support the primary work.

Why Were OLMs Introduced?

The GSA introduced OLM to make contracting simpler. Before OLM existed, agencies had to create separate contracts for every little add-on. That meant more paperwork. More time. More headaches for everyone involved.

Now? Agencies can bundle these items into existing orders. Contractors can offer more complete solutions. Everyone saves time.

Common Examples of OLM

Here’s the key: OLM items must directly support your main contract work. They can’t be random purchases that happen to occur at the same time. There has to be a clear connection.

For IT services, you might include software licenses or computer equipment. Professional services often need training materials or reference guides. Engineering contracts could require testing equipment or specialized tools.

For example, imagine a contractor working on a government project to build a new office building. The primary contract may focus on the construction of the building itself, but the contractor may need to purchase specific materials, such as furniture or specialized equipment, to complete the project. If the contractor orders ergonomic office chairs and desks to outfit the building, these items would qualify as OLMs because they are directly related to the completion of the building and essential for its intended purpose. However, if the contractor buys office supplies like pens or paper that are not needed for the construction work itself, those would not qualify as OLMs.

How GSA OLM Works

OLM items are priced and identified at the order level rather than at the time of Schedule award.

The structure is straightforward. You maintain your regular GSA Multiple Award Schedule contract. Within that contract, you have the ability to offer OLM alongside your main services.

When an agency places an order, they identify which parts are your core services. Then they specify what OLM items they need. Everything flows through one purchase order.

What Changed for GSA OLM in 2026?

Recent MAS updates changed how contractors can use the OLM SIN under the GSA Schedule program. These updates expanded access to OLM and removed several older restrictions that previously limited its use.

2026 Update	What Changed
OLM eligibility expanded	All GSA MAS contractors can now hold the OLM SIN under MAS Refresh 31.
33.33% cap removed	OLMs no longer have a fixed percentage limitation on task or delivery orders.
Fixed-price orders allowed	OLMs can now support fixed-price orders, along with T&M and labor-hour orders.
“Open Market” terminology updated	GSA now refers to open market items as “Non-MAS items” under newer ordering procedures.
Updated GSAR references	OLM procedures moved under GSAR 538.71 as part of the FAR overhaul updates.

Who Is Eligible for the OLM SIN?

As of MAS Refresh 31 in April 2026, all GSA MAS contractors are eligible to hold the OLM SIN. OLM still cannot be used as a standalone SIN and must support another MAS SIN on the order.

Check the GSA’s official list to see if yours qualifies.

Even if your category is authorized, you need to follow specific rules:

Your OLM offerings must relate to your main contract.
They must stay within reasonable pricing guidelines.
And you must maintain accurate documentation.

Agencies buying OLM also have responsibilities:

They need to justify why the OLM items are necessary.
They must ensure prices are fair and reasonable.
And they have to show how everything connects to the primary contract purpose.

Both contractors and ordering agencies are responsible for maintaining proper documentation and verifying compliance requirements.

GSA OLM Requirements Contractors Need to Know

Contractors using the OLM SIN must follow several ordering and compliance requirements under the GSA Schedule program.

Requirement	What It Means
Direct support of the order	OLM products or services must support the primary purpose of the task or delivery order.
Cannot be the main purpose	OLMs cannot become the primary focus of the contract order.
Pricing review applies	Ordering agencies must determine that OLM pricing is fair and reasonable at the order level.
OLMs must be clearly identified	Contractors must separate OLM items from other Schedule items within the order documentation.
IFF still applies	OLM sales are treated as GSA Schedule sales and are subject to the Industrial Funding Fee (IFF).
Sales reporting is required	Contractors must include OLM sales in GSA sales reporting.
Commercial item rules still apply	OLM products and services must meet commercial item requirements under federal acquisition regulations.
Compliance obligations remain in place	TAA requirements, cybersecurity rules, and supply chain restrictions still apply to OLM purchases when required under the contract.

How to Order OLM Under GSA Schedules

The ordering process differs slightly for agencies and contractors:

For Federal Agencies

You’ve identified a need for Order Level Materials. Great. Here’s your path forward:

Step 1: Confirm the contractor’s schedule includes OLM authorization. Contractors should confirm that the OLM SIN is included on the MAS contract before proceeding.
Step 2: Determine exactly what OLM items you need. Be specific. Vague requests create confusion and slow everything down.
Step 3: Verify the OLM directly supports your main contract purpose. Document this connection. Your contracting officer will need it.
Step 4: Review pricing to ensure it’s fair and reasonable. Compare against market rates if necessary.
Step 5: Include the OLM requirements in your task order or delivery order. Separate them clearly from your main service requirements.
Step 6: Maintain thorough records. Track what you bought, why you bought it, and how it supported the mission.

For Contractors

Want to add OLM capability to your GSA schedule? Here’s what that looks like:

First: Confirm the OLM SIN is active on your MAS contract before offering OLM items.
Assuming you’re eligible: Prepare your OLM offerings. List what you can provide. Describe how these items support your main services. Include pricing information.
Submit a modification to your GSA schedule: This isn’t a new contract. It’s an update to your existing one. The paperwork is less intensive than the original application, but it still requires attention to detail.
Provide clear justification for your OLM items: Explain the connection to your core services. Show why agencies would logically need these items alongside your main offerings.
Once approved: Update your GSA Advantage listings. Make sure agencies can see your OLM capabilities. Don’t hide this service. Market it.

Why Documentation Matters

Both agencies and contractors need solid records. What was ordered? When? Why? How much did it cost?

These records protect everyone. Think of documentation as your insurance policy. You hope you never need it. But when questions arise, you’ll be really glad it exists.

How to Add the OLM SIN to Your GSA Schedule

Adding the OLM SIN to a GSA Schedule contract usually happens through a Mass Modification or contract modification process.

Step	What Contractors Need to Do
Confirm OLM eligibility	Verify that your MAS contract is active and eligible for the OLM SIN under current GSA rules.
Review Mass Mod notifications	GSA may issue a Mass Modification offering the OLM SIN to MAS contractors.
Accept the Mass Modification	Contractors must accept the Mass Mod before the OLM SIN becomes active on the contract.
Submit a modification if needed	If the OLM SIN was not added through Mass Mod, contractors can request it through eMod.
Update GSA Advantage	The OLM SIN should appear in your GSA Advantage pricelist, even though specific OLM items are not pre-listed.
Report OLM sales correctly	OLM sales must be included in GSA sales reporting and IFF calculations.

OLM vs ODC: What’s the Difference?

People often confuse Order Level Materials with Other Direct Costs. They’re not the same thing. Let’s clear this up.

Aspect	OLM (Order Level Materials)	ODC (Other Direct Costs)
Definition	Products or services bought under GSA schedules that support the main contract	Additional costs directly tied to contract performance but not in the base price
Examples	Software licenses, equipment, training materials	Travel expenses, printing costs, shipping fees
Pricing	Must follow GSA pricing guidelines and be pre-approved	Reimbursed at actual cost or pre-negotiated rates
Authorization	Requires the OLM SIN on the MAS contract	Typically negotiated in individual task orders
Purchase Process	Ordered through GSA schedule as part of a delivery order	Billed separately, often with receipts and documentation
Purpose	Provides tangible items that enhance service delivery	Covers incidental expenses necessary for contract completion

The key distinction? OLM involves actual products or services you’re selling. ODC covers expenses you incur while performing the work.

If you buy something to resell as part of your solution, that’s OLM. If you spend money to get the work done, that’s ODC.

OLM vs Non-MAS (Open-Market): What’s the Difference?

Here’s another comparison that trips people up. OLM and Open Market Items sound similar. They’re actually quite different:

Aspect	OLM (Order Level Materials)	Open Market Items
Contract Vehicle	Must be purchased through GSA schedules	Can be bought from any vendor, with or without a contract
Authorization	Requires specific authorization in GSA subcategory	No special authorization needed
Relationship to Main Contract	Must directly support the primary GSA contract work	May or may not relate to any existing contract
Pricing Controls	Subject to GSA pricing rules and documentation	Subject to open market competition and price reasonableness
Documentation	Must be documented within the GSA order	Follows standard procurement documentation
Restrictions	Must support the primary MAS order and follow OLM requirements	Generally unrestricted based on availability
Vendor Requirements	Must be offered by a GSA schedule holder	Any qualified vendor can participate

OLM vs Ancillary SINs

Order-Level Materials and Ancillary SINs both support purchases made under the GSA Schedule program, but they are used in different situations.

OLM	Ancillary SINs
Products or services are identified and priced at the order level.	Products or services are already known and priced at the Schedule level.
Used for items that were not defined at the time of contract award.	Used for items already included under the contractor’s MAS contract.
Pricing is reviewed during the task or delivery order process.	Pricing is established during the original Schedule award or modification.
Must directly support the primary order.	Must support the contractor’s awarded SIN offerings.
Added through the OLM SIN.	Added under an Ancillary SIN on the MAS contract.

Need Help Navigating GSA Order Level Materials?

GSA contracting has layers. Order Level Materials add another dimension to consider. Managing OLM requirements alongside MAS compliance can create additional administrative and reporting responsibilities.

That’s where Road Map Consulting comes in.

We’ve spent years helping businesses understand and maximize their GSA schedules. OLM is just one piece of that puzzle, but it’s an important piece. We help you determine if OLM makes sense for your business. We guide you through the modification process to add OLM capabilities. And we make sure you’re using OLM correctly once it’s part of your schedule.

Our services include:

GSA OLM Explained: Rules, 2026 Updates, and Contractor Requirements