U.S. General Services Administration
Implement the new economic price adjustment clause
What’s new with EPA clause 552.238-120
EPA clause 552.238-120 replaces two older EPA clauses that governed Multiple Award Schedule contracts: I-FSS-969 and 552.216-70. MAS Refresh 29 officially retired the old clauses and incorporated 552.238-120.
What stays the same
All of the former EPA method and mechanism options are still available, but you’ll need to manually incorporate them into each offer or existing contract.
Incorporate the method and mechanism for
Offers
Submission before Refresh 29
Your assigned contracting officer or contract specialist — your CO or CS — will prompt you to accept the most current refresh and update your documentation, if needed.
Submission after Refresh 29
The solicitation will contain the current requirements and guidance regarding the new EPA clause. Provide the required info in the pricing terms section of the price proposal template before submitting your offer.
Existing contracts
There’s a simple process to include your chosen EPA method under the new EPA clause. This request will allow you and the government to resolidify your EPA method under the provisions of the new clause.
Accept Refresh 29
To remove the two legacy clauses and incorporate the new one. You should do this as soon as possible, but you must do it before Nov. 26, 2025, (90 days after we issued Refresh 29).
Voluntarily incorporate the Revise T&C mod
You can and should proactively do so before a triggering event.
Incorporate the applicable EPA method and mechanism into your contract
Through a Revise T&C mod. This must happen before one of these three triggering events occur:
- Submission of an EPA modification request: Any contractor request for an EPA-related pricing adjustment.
- Submission of any addition modification, such as add product, add labor category, add SIN, and so forth.
- Option to renew contract: Exercise of option periods or option-related modifications.
About the method and mechanism
Method
The method is the agreed upon procedures that dictate how an adjustment will be applied over time.
The method provides predictability and contract clarity through elements such as:
- Timing of increases
- Frequency of increases
- Any limits that may apply
- The mechanism
Mechanism
The mechanism is what the EPA is based on and refers to the tool or basis used to make the adjustment. The mechanism can be:
- Fixed escalation rates
- A market index or other basis
- Established pricing
Available mechanisms to make adjustments include:
GSAM 538.270-4(a)(1)
Based on fixed escalation rates
GSAM 538.270-4(a)(2)
Based on a market index
or other basis
GSAM 538.270-4(a)(3)
Based on established pricing
Example: If a contractor proposes a 3% fixed escalation, this is the mechanism. The mechanism combined with the limitation of an annual increase on the contract anniversary date together make up the EPA method.