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General Services Administration (GSA) 

Multiple Award Schedule (MAS) 

Special Item Number (SIN) 518210C

Ordering Guide

Version 2.1 

30 June 2022

TABLE OF CONTENTS:

A. Introduction to SIN 518210C 4

1. Roles and Responsibilities 4

a. GSA responsibilities 4

b. Ordering Activity responsibilities 5

2. Definitions 5

B. SIN 518210C Cloud Computing and Cloud Related IT Professional Services Explained 6

1. Cloud Computing Defined 6

2. How Cloud Computing is Sold 7

C. SIN 518210C Ordering Guide Steps 8

1. Perform Market Research 8

2. Draft Your Requirements 9

a. Application Rationalization 9

b. Consider a Cloud Blanket Purchase Agreement (BPA) 9

c. Acquisition Strategies 10

d. The Cloud Independent Government Cost Estimate (IGCE) 10

e. Choice of Contract Type 11
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f. Authorized Reseller vs. CSP (direct) 14

g. Multi-Cloud Strategy for IaaS and PaaS? 14

h. Cloud Computing as a Set Aside? 15

i. FedRAMP 15

j. Term Services and Period of Performance (PoP) Alignment 17

k. Additional Available Resources 17

3. Governance 19

4. Fund the Acquisition 20

5. Issue a Solicitation 21

a. eBuy: 21

b. SAM.gov: 21

6. Evaluation of Responses 21

7. Make an Award 22

Appendix A: GSAR Clause 552.238-199 23

Appendix B: Examples of Consumption Based Ordering 27
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Disclaimer of Liability or Endorsement:

The U.S. General Services Administration (GSA) expressly disclaims liability for errors and omissions in 

the contents of this document. No warranty of any kind, implied, expressed, or statutory, including but 

not limited to the warranties of non-infringement of third party rights, title, merchantability or fitness for a 

particular purpose, is given with respect to the contents of this document or its links to other Internet 

resources.

The information appearing in this document is for general informational purposes only. Reference in 

this document to any specific activity (e.g., event, meeting, training), commercial product, process, or 

service, or the use of any trade, firm or corporation name is for the education, information, and 

convenience of the government and public, and does not constitute endorsement, recommendation, or 

favoring by GSA.

GSA does not control or guarantee the accuracy, relevance, timeliness, or completeness of information 

contained on a website linked to by this document; does not endorse the organizations sponsoring any 

linked websites; does not endorse the views they express or the products/services they offer; cannot 

authorize the use of copyrighted materials contained in linked websites. Users must request such 

authorization from the sponsor of the linked website.
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A. Introduction to SIN 518210C

The GSA Multiple Award Schedule (MAS) are long-term governmentwide contracts with 

commercial firms providing federal, state, and local government buyers access to more than 11 

million commercial supplies (products) and services at volume discount pricing. 

MAS contains the Special Item Number (SIN) 518210C, Cloud Computing and Cloud Related 

Information Technology (IT) Professional Services, specifically for just cloud services authorized 

vendors. SIN 518210C may be utilized by federal Ordering Activities as well as state, local, 

tribal organizations, certain educational institutions, international organizations, and other 

eligible users outlined in GSA Order OGP 4800.2I. 

SIN 518210C contains over four hundred authorized vendors of cloud computing services as of 

June 2022, and growing. It also includes cloud related IT professional (labor) services. 

Therefore, Ordering Activities may solicit to contractors providing SIN 518210C on their 

schedule contract to find cloud services and cloud related IT cloud professional services (labor). 

SIN 518210C contains only cloud services that meet the National Institute of Standards and 

Technology (NIST) definition of cloud. When multiple requirements are needed, Ordering 

Activities should only select SIN 518210C when submitting a RFQ on eBuy and state that 

authorized contractors may utilize other SINs to create a complete solution. Examples would be 

soliciting the Software SIN (SIN 511210) for software that is not cloud based (and so does not fit 

the NIST definition) but runs in the cloud and/or manages other cloud offerings, or the 

Hardware SIN (SIN 33411) for private cloud requirements since no hardware for private clouds 

is listed on the SIN 518210C.

This SIN 518210C Ordering Guide will only provide guidance to Ordering Activities. It will not 

prescribe or limit what cloud services contractors provide, nor is it binding to Ordering Activities 

as they will have to execute in accordance with their Ordering Activity policies and practices. 

This Guide is intended to be a living document and will be updated periodically, as needed.

For a deeper discussion of the topics discussed in this guide, please refer to the GSA MAS 

Desk Reference.

1. Roles and Responsibilities 

GSA is responsible for the award, administration, and management of the GSA Multiple Award 

Schedule (MAS) Solicitation and the Information Technology Category Attachment to the 

Solicitation. The Ordering Activity is responsible for the award, administration, management, 

and closeout of task orders placed against the GSA MAS Contract and compliance with its 

terms and conditions, the Federal Acquisition Regulation (FAR), and local Ordering Activity 

policies, as applicable.

a. GSA responsibilities

● Administer the GSA MAS Information Technology Category, including annual 

subcontracting goal reporting, contract modifications to implement new FAR guidance, 

and updating the terms and conditions.
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● Provide advice and guidance to Ordering Activities regarding specific cloud acquisition 

matters, by emailing the GSA Cloud Team at cloudinfo@gsa.gov.

● Determines “fair and reasonable” prices and ceiling prices for a single unit when 

awarding GSA contracts. 

b. Ordering Activity responsibilities

● Define order requirements (technical, security, operational, workflow, functional, etc.), 

including evaluation criteria. 

● Prepare requirements documents for solicitations against contracts. This includes a 

Statement of Work (SOW) or Performance Work Statement (PWS) for task orders (TO) 

and product listings and other necessary information for delivery orders (DO).

● Properly manage funds in accordance with (IAW) appropriation laws and their Ordering 

Activity rules and regulations.

● Evaluate quotes IAW the Federal Acquisition Regulation (FAR) and the Ordering Activity 

defined evaluation criteria. 

● Monitor performance, including appointing a Contracting Officer’s Representative (COR) 

when applicable.

● Negotiate pricing, discounts, and other Simplified Acquisition Threshold (SAT) pricing 

with authorized vendors when applicable. 

2. Definitions

● Ordering Activity Contracting Officer (OACO): the Ordering Activity warranted 

Contracting Officer (CO) placing the order. 

● Office of the Chief Acquisition Officer (OCAO): the team responsible for developing and 

reviewing acquisition policies, procedures and related training for the Ordering Activity.

● GSA Contracting Officer (CO): a person with the authority to enter into, administer, 

and/or terminate contracts and make related determinations and findings. The GSA 

CO administers the GSA MAS contract. 

● Special Item Number (SIN): the unique identification number assigned to specific 

product or service categories under the GSA MAS Solicitation. 

● Contractor Team Arrangement (CTA): two or more GSA MAS authorized contractors 

working together to provide a total solution to the Ordering Activity, whereby each is 

working under their respective GSA MAS contract awards. This is not a prime/sub 

arrangement. See www.gsa.gov/cta for more information. 

● Ordering Activity: a federal, state, or local government Ordering Activity or other eligible 

entity that is authorized to use SIN 518210C. 

● Cooperative Purchasing Program: authorized Ordering Activities, per 40 U.S.C. 502(c), 

may leverage SIN 518210C under the GSA Cooperative Purchasing Program. Eligibility 

to use GSA Sources of Supply. 

● Disaster Purchasing Program: authorized Ordering Activities, per 40 U.S.C. 502(c), may 

leverage SIN 518210C under the GSA Disaster Purchasing Program to facilitate disaster 

preparation, response, or major disaster recovery.

● Authorized Reseller: an entity that has been contractually authorized by a cloud service 

provider (CSP) to act as an authorized agent or intermediary cloud broker to offer, 

negotiate, and sell, on the behalf of the CSP, the CSP's cloud services.
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● Authorized Contractor: an entity that has been awarded SIN 518210C Cloud Computing 

and Cloud Related IT Professional Services on their GSA MAS award. An authorized 

vendor can be either a CSP or an authorized reseller.

● Cloud Service Provider (CSP): an entity that directly operates and manages the cloud 

services (i.e., IaaS, PaaS, SaaS) technology (e.g., facility, hardware, software).

B. SIN 518210C Cloud Computing and Cloud 

Related IT Professional Services Explained

1. Cloud Computing Defined

For this document we use the definition of "cloud" by the National Institute of Standards and 

Technology (NIST) Special Publication 800-145 The NIST Definition of Cloud Computing. 

Traditionally an Ordering Activity would purchase hardware and/or software infrastructure 

outright as well as unboxing it, racking, stacking and wiring it, configuring it, etc. With cloud 

computing, an Ordering Activity remotely orders virtual machines, applications and more at the 

touch of a button. 

The National Institute of Standards and Technology (NIST) definition of cloud computing is 

broken down into these five distinct characteristics:

● On Demand Self Service – A consumer can unilaterally provision computing capabilities, such 

as server time and network storage, as needed automatically without requiring human 

interaction with each service provider.

● Rapid Elasticity – Capabilities can be elastically provisioned and released, in some cases 

automatically, to scale rapidly outward and inward commensurate with demand. To the 

consumer, the capabilities available for provisioning often appear to be unlimited and can be 

appropriated in any quantity at any time.

● Broad Network Access – Capabilities are available over the network and accessed through 

standard mechanisms that promote use by heterogeneous thin or thick client platforms (e.g., 

mobile phones, tablets, laptops, and workstations).

● Resource Pooling – The provider’s computing resources are pooled to serve multiple 

consumers using a multi-tenant model, with different physical and virtual resources dynamically 

assigned and reassigned according to consumer demand. There is a sense of location 

independence in that the customer generally has no control or knowledge over the exact 

location of the provided resources but may be able to specify location at a higher level of 

abstraction (e.g., country, state, or datacenter). Examples of resources include storage, 

processing, memory, and network bandwidth.

● Measured Service – Cloud systems automatically control and optimize resource use by 

leveraging a metering capability at some level of abstraction appropriate to the type of service 

(e.g., storage, processing, bandwidth, and active user accounts). Resource usage can be 

monitored, controlled, and reported, providing transparency for both the provider and consumer 

of the utilized service.

To be considered cloud computing by this definition, the cloud service must possess all of the 

above five characteristics. 
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There are three primary cloud service models you can purchase:

● IaaS (Infrastructure as a Service) – The capability provided to the consumer is to provision 

processing, storage, networks, and other fundamental computing resources where the 

consumer is able to deploy and run arbitrary software, which can include operating systems and 

applications. The consumer does not manage or control the underlying cloud infrastructure but 

has control over operating systems, storage, and deployed applications; and possibly limited 

control of select networking components (e.g., host firewalls).

● PaaS (Platform as a Service) – The capability provided to the consumer is to deploy onto the 

cloud infrastructure consumer-created or acquired applications created using programming 

languages, libraries, services, and tools supported by the provider. The consumer does not 

manage or control the underlying cloud infrastructure including network, servers, operating 

systems, or storage, but has control over the deployed applications and possibly configuration 

settings for the application-hosting environment.

● SaaS (Software as a Service) – The capability provided to the consumer is to use the 

provider’s applications running on a cloud infrastructure . The applications are accessible from 

various client devices through either a thin client interface, such as a web browser (e.g., webbased email), or a program interface. The consumer does not manage or control the underlying 

cloud infrastructure including network, servers, operating systems, storage, or even individual 

application capabilities, with the possible exception of limited user specific application 

configuration settings.

You must also choose a deployment model. Deployment models detail how many separate, 

multi-tenants are in the cloud environment and what the relationship between these tenants is. 

There are four NIST cloud deployment models:

● Public Cloud – The cloud infrastructure is provisioned for open use by the general public. It 

may be owned, managed, and operated by a business, academic, or government organization, 

or some combination of them. It exists on the premises of the cloud provider.

● Private Cloud – The cloud infrastructure is provisioned for exclusive use by a single 

organization comprising multiple consumers (e.g., business units). It may be owned, managed, 

and operated by the organization, a third party, or some combination of SIN 518210C.

● Community Cloud – The cloud infrastructure is provisioned for exclusive use by a specific 

community of consumers from organizations that have shared concerns (e.g., mission, security 

requirements, policy, and compliance considerations). It may be owned, managed, and 

operated by one or more of the organizations in the community, a third party, or some 

combination of them, and it may exist on or off premises. 

● Hybrid Cloud – The cloud infrastructure is a composition of two or more distinct cloud 

infrastructures (private, community, or public) that remain unique entities, but are bound 

together by standardized or proprietary technology that enables data and application portability 

(e.g., cloud bursting for load balancing between clouds).

2. How Cloud Computing is Sold

Most of the cloud computing pricing models require careful analysis by Ordering Activity personnel 

based on the unique attributes of their acquisition. Many pricing models require ongoing monitoring of 

usage and available funding. See the discussion on choosing contract types later in this document for 

guidance on using a not-to-exceed (NTE) ceiling price by CLIN.
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● IaaS/PaaS priced by the Increment (e.g., transaction, Minute, Seconds, Hours or Days), for 

central processing units (CPUs), storage or memory for virtual machines in the cloud 

environment. Depending on the contract type awarded, this may cause invoices to vary from 

month to month. In the case of communications application programming interface (API) 

platforms that charge by short message service (SMS) message/email sent or voice minutes 

used.

● SaaS priced by the Seat (e.g., application user seat), most commonly by the seat per month or 

seat per year.

● SaaS priced by the Transaction (e.g., up/download, operation), as in the case of large online 

databases. Login may or may not be free of charges, but a per transaction charge accrues 

whenever the customer issues a query against that large database (e.g., real estate or scientific 

applications). Another example, for SaaS, might be a charge for each read/write disk operation, 

sometimes sold in dollars per 10M operations, etc. 

● IaaS/PaaS priced by Data Transport, is calculated from the transport of data into/within/out of 

the data center. 

● IaaS/PaaS priced by Service Term (e.g., time period), sometimes called “reservations,” 

“reserved instances” (RIs), “committed use” or “savings plans”, each CSP has their own specific 

term for the offering. For the purpose of this document we will refer to them as the generic 

term “cloud reservations”. These are commitments to purchase compute capacity, or buckets 

of transactions, needed for your Ordering Activity over a defined and agreed to period of time, 

usually in exchange for a discount. Cloud reservations are allowed per the GSA MAS 

Solicitation, as long as they are paid for in arrears (31 U.S.C. 3324). They are recommended for 

workloads that have steady or predictable usage patterns. These “cloud reservations” offer a 

discount against on-demand pricing (per minute, etc.) depending on length of term, whereas 

volume discounts offer a tiered discount that depends on certain thresholds.

C. SIN 518210C Ordering Guide Steps

1. Perform Market Research

There are many ways to perform market research: GSA’s Market Research as a Service 

(MRAS), Small Business Administration (SBA) resources, Defense Acquisition University (DAU) 

resources, etc. You are encouraged to look at the options that align with your Ordering Activity’s 

needs. 

GSA’s Market Research as a Service (MRAS) Tool lessens much of the frustration that the back and 

forth market research process may have. MRAS utilizes the latest automated research techniques to 

collect authorized vendor response data. This no-cost service cross-indexes Ordering Activity 

requirements against authorized contractors on SIN 518210C that support cloud. 

To initiate a MRAS, an Ordering Activity will:

1. Engage their GSA Customer Service Director (CSD): Contact your CSD who 

will help guide you through this process.

2. Request a Scope Review: The GSA CSD and the Subject Matter Experts 

(SMEs) for the applicable GSA vehicle will review the requirement to determine if 

it is within scope of one of the various GSA contracts (Governmentwide 

Acquisition Contract (GWAC), OASIS, MAS, VETS2, etc.).
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3. Request a Request for Information (RFI) from MRAS team: The GSA CSD 

and Ordering Activity will together fill out a short requirements questionnaire so 

that the MRAS team can create a RFI.

GSA will then publish a market research RFI on behalf of the Ordering Activity, allowing GSA to 

gather authorized contractor responses for an agreed upon period of time. After that time 

elapses, GSA collects and collates the results and delivers a report to the Ordering Activity. The 

report details the total number of interested authorized contractors, their relevant GSA contracts 

specific to the requirements, their socioeconomic profiles, their business size, their responses to 

specific yes/no technical questions, and more. Check out full MRAS samples here (A, B). 

The responses gathered from the market research may cause you to rethink choices of contract 

type and other requirements. In that case you must loop back to revise your requirements.

2. Draft Your Requirements

a. Application Rationalization

The authorized Ordering Activity should first complete the Application Rationalization 

(AppRat) process. This typically includes:

● inventorying the digital environment

● assessing which applications are cloud ready and which are not

● determining which are high strategic business value

● discovering which are underutilized

● seeing which should be kept and which should be retired

● finding system/services inter-decencies required supporting services/data

Once the Application Rationalization process has been completed, it is time for the 

program/technical team, along with the acquisition team, to draft the formal cloud 

services requirements and acquisition strategy.

If an Ordering Activity chooses to use cloud professional services for the Application 

Rationalization process, it is recommended to do this as a standalone award, and that 

deliverable becomes the requirements for a second award to execute the migration to a 

CSP’s cloud. Also, the authorized Ordering Activity can require demonstrated 

experience with similar size, scope, and subject matter expertise of projects, with 

applicable CSP certifications, if available.

b. Consider a Cloud Blanket Purchase Agreement (BPA)

Ordering Activities can award BPAs (FAR 8.405-3) against the GSA MAS SIN 518210C.

Ordering Activities award BPAs (i.e., multiple award or single award (see limitations: GSA, FAR 

8.405-3)) when an authorized Ordering Activity defines requirements (e.g., business, 

operations, security, technical) that allow the authorized Ordering Activity to issue BPA awards 

to authorized contractors that meet the BPA requirements. The authorized Ordering Activity, 

and other authorized Ordering Activities, can then use the BPA to compete TOs against the 

BPA awardees. The TOs inherit the BPA requirements and can include additional requirements 

or further define and delineate the requirements (e.g., quantities). An awarded TO results in the 
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legally binding "contract" between the Ordering Activity and the authorized contractor. (Note: 

Per FAR 8.405-3, they are referred to as TOs, not Orders, as SIN 518210C is a service, not a 

product.) When any TO is created, decisions about contract type and funding type could be 

made at that time depending on the nature of the cloud computing requirement.

c. Acquisition Strategies

● Distributed/Office Level: Supports a distinct and individual TO for specific, defined, and known 

set of requirements. 

Here, the cloud services acquisition journey begins with what can be the most difficult step for 

some: defining your cloud service requirements. Requirements must be developed for each 

application so that they can be cloud-migrated or cloud-developed (i.e, Application 

Rationalization). The result is that the target cloud architecture is defined for each application 

before it is migrated to the appropriate/available cloud environment(s). This structured project 

process is no different from a non-cloud project. 

● Enterprise/Chief Information Officer (CIO) Level: Development of a BPA that defines 

baseline requirements for specific recurring needs of an Ordering Activity with TO(s) awarded 

under the BPA for specific quantities and deliverable times.

Here the cloud services acquisition journey begins with reviewing current Ordering 

Activity cloud utilization and defining the overall goals and objectives of establishing an 

enterprise-wide purchasing vehicle (centralization, governance, risk management, cost 

savings, etc.).

● Other acquisition strategies to consider:

○ Best practice is to separate the procurement of cloud services (IaaS, PaaS, 

SaaS) from the cloud related IT professional services (labor) often associated 

with the cloud (e.g., architecting, migration, configuration etc.). Awarding the IT 

professional services to a different Authorized Contractor may provide unbiased 

support. This provides the greatest flexibility in utilizing in-house resources 

(Ordering Activity or contractor) with the best knowledge of existing systems for 

delivering professional services.

○ Before seeking to leverage emerging technologies, conduct due diligence to 

ensure the likelihood of success. Untested emerging technologies may not meet 

early expectations for performance or may not integrate into Ordering Activity 

operations as initially anticipated. Ordering Activities should evaluate which 

services are available that meet Ordering Activity/federal security requirements.

d. The Cloud Independent Government Cost Estimate (IGCE)

The primary way in determining if "a price is reasonable'' is to develop a cost estimate 

(e.g., IGCE) and evaluate proposals in comparison to the developed cost estimate. The 

Ordering Activity should check with their own internal supplemental acquisition 

regulations, policies, and the FAR to understand if an IGCE is required for their specific 

cloud services procurement. Typically, the Ordering Activity must first estimate the value 
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of the acquisition and if that estimated value exceeds the Simplified Acquisition 

Threshold (SAT), then they are required to conduct market research.

An IGCE is a complex undertaking for cloud services as individual cloud stock keeping 

units (SKUs) need to be compared in an apples-to-apples way since they are sometimes 

tied to a specific authorized contractor. If available, universal product codes (UPCs) 

should be used at the CSP level when comparing products. Best practice is to ask the 

CSP or authorized reseller the structure of their cloud service offerings and how they 

map across their commercial cloud services ecosystem.

Another suggestion is to create a set of technical requirements for the entire portfolio of 

Ordering Activity applications to be hosted in the cloud. Then, visit the websites of 

several CSPs and use the CSPs’ online calculators to help create the IGCE. The 

calculators provide public pricing that can be used in conjunction with other sources for 

compiling an IGCE. These calculators are another tool in an Ordering Activity’s tool kit, 

but Ordering Activities should also attempt to find other ways to INDEPENDENTLY 

estimate costs. Note: not all CSPs price their solutions in the same manner; it is 

important to clearly understand how each CSP prices offerings, costs elements and noncost elements. It takes time to research, understand, and map those elements to your 

IGCE.

When performing a price analysis during market research, consider an approach with 

emphasis on pursuing volume discounts (which may be a tiered set of discounts based 

on volume vs. fixed discounts) and enterprise-wide pricing. Ordering activities can 

maximize cost savings by driving Ordering Activity cloud service customers toward an 

enterprise-wide cloud computing ordering approach (e.g., two-three Ordering Activitywide cloud orders or BPAs managed by one program office) instead of each program 

office issuing individual orders for cloud computing. Similarly, consolidating various IT 

services under fewer contracts can also generate volume discounts. Like with any other 

product or service, true savings for cloud computing is realized when customers 

combine their cloud services requirements and leverage their buying power as a large 

volume customer. The Ordering Activity CIO (under Federal Information Technology 

Acquisition Reform Act (FITARA)) has to approve these actions to ensure enterprise 

level deployment.

e. Choice of Contract Type

The contract type suggestions below are for GSA MAS Solicitation cloud services (e.g., 

IaaS, PaaS, SaaS) plus associated tools for automated managed services which are 

often billed as SaaS. The choice of contract type (i.e., fixed price, labor, or time-andmaterial) for cloud related IT professional services (work performed by humans), should 

be considered separately. To learn more, please reference the “GSA Multiple Award 

Schedule Ordering Guide Quick Reference Summer 2020”. 

It’s important that the Ordering Activity identifies if the cloud services will have a baseline 

utilization that does not fluctuate over the period of performance, or if utilization will have 

high fluctuation/surge that would benefit from consumption/utilization-based pricing. This 

will guide your choice of contract type. 
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● Requirements Type Task Orders: As discussed in the GSA Acquisition Letter (AL) MV21-06, Procurement of Cloud Computing on a Consumption Basis under the Federal 

Supply Schedule (FSS) program, GSA proposed a requirements task order framework to 

buy cloud on a consumption basis, and proposed facilitating incremental funding via 

optional CLINs. (see Appendix A for General Services Acquisition Regulation (GSAR) 

Clause 552.238.199 Special Ordering Procedures Applicable when Procuring Cloud 

Computing on a Consumption Basis (MAR 2022) and an example in Appendix B). This 

task order type is appropriate when the authorized Ordering Activity anticipates recurring 

requirements but cannot predetermine the precise quantities of cloud computing 

services that designated government activities will need during a definite period.

NOTE: The special ordering procedures clause (GSAR Clause 552.238.199 Special 

Ordering Procedures Applicable when Procuring Cloud Computing on a 

Consumption Basis (MAR 2022)) is only required, per (c)(1), "when placing an 

incrementally funded task order under this contract for cloud computing services 

on a consumption basis." Otherwise, the clause is optional. Nothing in GSAR 

552.238-199 shall be construed to supersede the Ordering Activity’s contract 

funding policies (GSAR 552.238-199(f)(3))

● Consumption Framework

○ Ordering activities can do this today but current policies don’t provide a 

roadmap for how to implement a consumption framework. Per GSA’s 

Acquisition Letter (AL) MV-21-06 Supplement 1, dated March 18, 2022, 

adding GSAR Clause 552.238-199 into the MAS Solicitation allows 

Ordering Activities to use a “requirements type task order” contract type, 

which is a “task order that provides for filling all actual purchase 

requirements of a designated authorized Ordering Activity during a 

specified contract period, with performance by the Contractor being 

scheduled when the authorized Ordering Activity awards, or exercises 

options for, individual contract line items (CLINs) under the task order.”

○ Well defined requirements lend themselves to the obligation of funding on 

a contract upfront, while unpredictable requirements might best be funded 

using optional CLINs that are funded at time of activation. But the core 

benefits of cloud include on-demand self-service and rapid elasticity, 

which supports agile development, DevOps, and unforeseen spikes in 

demand. If your requirements aren’t well defined, consider establishing 

predefined requirements on CLINs to be used later.

● Incremental Funding

○ The Antideficiency Act requires that whenever an Ordering Activity enters 

into a contractual obligation it must obligate funding sufficient to cover the 

contractual obligation. While this is necessary to meet the legal 

requirement, it can commit Ordering Activity funds in a manner that may 

preclude any alternative use of those funds.

Note: Ordering activities incur obligations and make expenditures while 

executing the funded programs, projects, and activities. An obligation is 

any action that legally binds the Ordering Activity to make an outlay or 
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expenditure of funds immediately or in the future. Expenditures may not 

exceed obligations, and corrective action must be taken promptly to 

validate the expenditures and obligation if it appears that they have.

○ When your actual cloud expenditure for the fiscal year is forecasted to not 

match the amount of funds obligated, you may need to obligate more 

money or deobligate excess funds on the contract. Make sure to 

coordinate such matters with your controller/financial organization (CFO) 

and legal counsel.

○ The main elements of Acquisition Letter MV-21-06 provide a framework 

for obligating funds “as you go” while providing safeguards to ensure you 

do not violate the Antideficiency Act. This policy requires Ordering 

Activities to obligate funding when optional CLINs are activated in 

accordance with FAR 17.2. This is not as fluid as private sector practices 

but it does provide a way for Ordering Activities not to obligate funds on 

optional CLINs until there is a bona fide need and those CLINs are 

activated.

Note: MAS BPAs have no ceiling value, only an estimate, so Ordering 

Activities can have many options without having to worry about using a 

ceiling like under an Indefinite-Delivery Indefinite-Quantity (IDIQ)/GWAC 

(e.g., STARS 8(a)). The ceiling value is only on the Ordering Activities 

awarded TO/PO. It is not easily increased (e.g., increase in scope), so the 

ceiling value should be estimated appropriately.

○ Selected referenced laws for incremental funding

■ DOD

● 10 U.S.C. 2306c - Armed Forces - Multiyear Contracts: 

Acquisition of Services

● 10 U.S.C. 2410a - Armed Forces - Contracts for Periods 

Crossing Fiscal Years: Severable Service Contracts; 

Leases of Real or Personal Property

■ Civilian

● 41 U.S.C. 3903 - Public Contracts - Multiyear Contracts

● 41 U.S.C. 3902 - Public Contracts - Severable Services 

Contracts for Periods Crossing Fiscal Years

Note: the above are not the full compendium of laws, others like 

31 U.S.C 1341, 31 U.S.C 1342, and 31 U.S.C 1517 pertaining to 

Anti-Deficiency Act may be applicable. 

○ Always consult your Ordering Activity’s Chief Financial Officer (CFO) and 

legal counsel for guidance on the specific laws, regulations, and 

authorities applicable to funding your order. 

● Fixed Price (FP) Model: This type of contract has the advantage of allowing changes to 

the number or complexion of cloud services at the touch of a button, but may not have 

the ability to reduce overall cost when not utilizing the cloud resource. If your agency has 

the ability to leverage more than one contract type, a blended/optimized solution may be 

possible. This blended model works best if an Ordering Activity has a good handle on 
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the baseline for cloud computing needs. A BPA might be used to combine FP, Time & 

Material (T&M), and Requirements Type models since each Task Order (TO) issued 

under a BPA can carry a different contract type.

● Time & Materials (T&M) Model: Since cloud services often accrue charges by the 

minute, hour, etc., charges will vary from invoice to invoice over the period of 

performance. (That’s the “T” in T&M.) Since FAR 16.601 only references hourly rates, 

agencies may need to define a method of calculating fractional hours if needed. This 

closely resembles invoices for work done on a labor contract. This type of contract fits 

most closely to the way charges for cloud services often accrue commercially. It is worth 

noting that the Federal Acquisition Regulation (FAR) only discusses the T&M model 

contract with respect to labor. So, agencies must rely on FAR 1.102(d), which essentially 

says that if the FAR does not expressly forbid it, then it is permissible. Though it will be 

up to the Ordering Activity’s CO to determine what they deem allowable for the agency.

There are certain requirements/limitations for T&M in accordance with FAR Part 12.07. 

For example, the CO must prepare a determination and findings (D&F) that shall be 

assigned and signed by the Head of Contracting Activity (HCA) or other official in 

accordance with agency policy, and additional approval required for contracts expected 

to extend beyond three years. Also, required with FAR 8.404(h)(3)(i)(B).

f. Authorized Reseller vs. CSP (direct)

Some CSPs sell directly while others prefer to sell via a network of authorized resellers. This 

arrangement is readily compared to a car manufacturer/dealer relationship. While it can be 

difficult to track down the cloud services you desire to an authorized reseller that sells it, there is 

an advantage to this arrangement. 

An IT customer may need access to more than one CSP for regulatory and/or technical 

reasons. An award to an authorized reseller that offers multiple CSP catalogs may reduce the 

number of acquisition actions needed. On the other hand, an award to a single CSP allows the 

Ordering Activity a more direct relationship to the CSP without a third party, which may result in 

the ability to obtain discounting as well as different customer support options.

The acquisition strategy will be driven by the Ordering Activity’s technical, performance, and 

management requirements which may or may not lend itself to authorized resellers or CSPs. 

The depth and breadth of the GSA MAS Solicitation provides the ability to meet varying needs.

g. Multi-Cloud Strategy for IaaS and PaaS?

An authorized Ordering Activity may decide to leverage cloud services (i.e. IaaS, PaaS, SaaS) 

from multiple CSPs, which means they are operating in a multi-cloud environment using a multicloud strategy to meet their requirements.

When an authorized Ordering Activity uses a multi-cloud strategy they are then able to 

determine which CSP's cloud services best satisfy their requirements (e.g., business, 

operations, security, technical) and deploy their workloads accordingly. A multi-cloud strategy 

may also allow Ordering Activities to take advantage of each CSP's evolving innovation and/or 

specialized services (e.g. machine learning, artificial intelligence). 
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It is important to note that these benefits accrue to enterprises that deploy and leverage 

the IaaS and PaaS of more than one CSP, not those that segregate their cloud business 

by standardizing with a single IaaS and PaaS provider and then working with various 

SaaS providers.

Ordering Activities could also consider employing a multi-cloud strategy, perhaps in conjunction 

with a BPA. There are cloud authorized resellers who can provide access to multiple CSPs. 

Requirements documents and solicitations can be structured to include access to multiple CSPs 

that meet a list of specified requirements. Solicitations can be designed to specify that 

authorized resellers must provide access to a particular CSP (as supported through the 

appropriate Brand Name Justification or Limited Source Justification) as well as access to “X” 

number of other CSPs whose cloud offerings meet a list of specified requirements as defined by 

the Ordering Activity. This way the Ordering Activity is guaranteed access to the CSP(s) that are 

currently hosting their architecture while allowing for the flexibility to access other CSPs that can 

be leveraged moving forward.

Multi-cloud buffers the Ordering Activity from the risk of CSP lock-in, which may reduce the 

fees/burden of an Ordering Activity when moving its data to a different CSP. Ordering Activities 

that cannot cost-justify or afford to take their cloud business from their current CSP to a 

competitor effectively forfeit negotiating leverage. An Ordering Activity might choose to make it a

requirement of the contract that the Authorized Contractor shall cooperate with other Authorized 

Contractors and government staff when transitioning between CSPs. 

h. Cloud Computing as a Set Aside?

Cloud computing services are frequently sold by small business authorized resellers of 

large CSP businesses’ cloud offerings. So you might think this is a good case for a small 

business set aside. 

However, the Small Business Administration (SBA) considers cloud computing as a 

service and not a product per CFR 121.1203(d)(3). Therefore the non-manufacturing 

rule (NMR) does not apply since the NMR only applies to products. Often the authorized 

reseller is a small business and the CSP is a large business, and more than 50% of the 

funding goes to the CSP, therefore no small business credit is given.

The bottom line is that a set aside for cloud computing will usually be indefensible. One 

exception is if the CSP itself is a small business (which is not common). Another 

exception is if the authorized reseller is a small business and the CSP is a large 

business and the “primary purpose” of the acquisition is not for cloud computing (which 

is not likely). 

Keep in mind that cloud computing is excluded from the limitations on subcontracting 

calculation where the small business concern will perform other cloud professional 

services that are the primary purpose of the acquisition, in accordance with 13 CFR 

125.6(a)(1).

i. FedRAMP

The Federal Risk and Authorization Management Program (FedRAMP) is a governmentwide 

program that promotes the adoption of secure cloud services across the federal government by 
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providing a standardized approach to security assessment, authorization, and continuous 

monitoring for cloud products and services.

FedRAMP eliminates duplicative efforts by providing a common security framework. Agencies 

review their security requirements against a standardized baseline. A CSP goes through the 

authorization process once, and after achieving an authorization for their Cloud Service Offering 

(CSO), the security package can be reused by any federal agency.

When thinking about FedRAMP, it is best to look at it from two different perspectives: acquisition 

versus security. 

● Acquisition

○ To accomplish the goals of the Competition in Contracting Act (10 USC 

§2304(a)(1), FedRAMP recommends against making a FedRAMP authorization 

a requirement for any cloud services procurement because it unfairly limits 

competition. 

○ The recommendation is to only require respondents to state what their FedRAMP 

status is, and to score possession of a FedRAMP authorization appropriately 

during the evaluation of responses. Ultimately, the authorized Ordering Activity 

CO will make the decision on FedRAMP being a requirement. 

● Security 

Once the Ordering Activity is in post award status, per the rules of the Federal 

Information Security Management Act (FISMA), each Ordering Activity CIO will still need 

to conduct their Assessment and Analysis (A&A) and issue an all encompassing 

Authority to Operate (ATO) for the CSO to go into production by using NIST Special 

Publication (SP) 800-53 rev. 5 Risk Management Framework (RMF), which is what 

FedRAMP uses per their Policy Memo. This ATO process should be more streamlined 

for success if the CSO already has a FedRAMP authorization. 

Obtaining a FedRAMP Authorization: 

There are two approaches for a CSP to obtain a FedRAMP Authorization (if one does not 

already exist), a provisional authorization through the Joint Authorization Board (JAB) or an 

authorization through an agency. 

1. In the Agency Authorization path, agencies may work directly with a CSP for 

authorization at any time. CSPs that make a business decision to work directly with an 

agency to pursue an ATO will work with the agency throughout the FedRAMP 

Authorization process.

2. In the JAB Authorization path, the JAB is the primary governing body for FedRAMP and 

includes the Department of Defense (DoD), Department of Homeland Security (DHS), 

and GSA. The JAB selects approximately 12 cloud products a year to work with for a 

JAB Provisional Authority to Operate (P-ATO). Additionally, the JAB is responsible for 

performing the continuous monitoring for all JAB Authorized cloud products.
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j. Term Services and Period of Performance (PoP) Alignment 

Ordering Activities can procure multi-year “cloud reservations” as long as the multi-year 

reservation falls within a single PoP. 

The execution of any cloud service (1 year reservation, 3 year reservation*) can not commit the 

Ordering Activity to incur costs beyond a CO awarded PoP.

● Example A: An Ordering Activity could not purchase a 3 year reservation under a 1 year 

PoP (e.g. base year, option year); the 3 year reservation extends beyond the PoP and 

would make the Ordering Activity incur costs outside of the executed PoP. They also can 

not execute the Base Year, Option Year 1, and Option Year 2 PoPs at the same time as 

only one PoP can be executed at a time.

● Example B: If using the Multi-Year Contracting special contracting method under FAR 

17.1 an Ordering Activity could potentially award a 5 year PoP in accordance with the 

requirements set forth at FAR 17.1. A 3 year reservation could be executed anytime in 

the 1st and 2nd year, but once the contract was 2 years and 1 day into the PoP the 

Ordering Activity would not be able to execute a 3 year reservation since the reservation 

period would extend beyond the end of the PoP. Please note that Contracting Officers 

will need to work with the finance organization, OCAO, and legal counsel before using 

Multi-Year Contracting and reservations greater than one year. 

From the examples above, you can see that procuring cloud services on SIN 518210C does not 

function the same as procuring perpetual software products from SIN 511210 Software 

Licenses. 

● With SIN 518210C Cloud Computing and Cloud Related IT Professional Services, the 

limitation is the PoP start/end dates; the cloud service stops on the PoP end date. 

● With SIN 511210 Software Licenses, the only concern is the incurred cost must happen 

before the PoP end date, since the software product can be used after the end date. 

The primary issues revolve around who in the Ordering Activity has the authority to commit the 

Ordering Activity to incur costs, which is the authority of a CO. The decision to execute an 

option also resides entirely with the CO.

* 3 year “cloud reservations” can be purchased with different types of appropriations (e.g., single 

year, multi-year, no year funds) per (10 U.S.C. 2306c - Armed Forces - Multiyear Contracts: 

Acquisition of Services and 41 U.S.C. 3903 - Public Contracts - Multiyear Contracts )

k. Additional Available Resources

GSA has a wide variety of support for your cloud acquisition depending on the phase 

you are currently in. Some of the more common services can be found below:

Note: The services listed below are easily acquired via Inter Agency Agreements 

(IAAs/Memorandum of Agreements (MOAs)), not contracting actions. These can be 

done at the Program/Product level.
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● GSA Federal Acquisition Service (FAS)

○ Office of Assisted Acquisition Services (AAS): GSA’s Office of Assisted 

Acquisition Services (AAS) provides custom acquisition, project, and financial 

management support services to federal Ordering Activities across the federal 

government for a fee. Ordering Activities may get the Contracting Officer services 

they need while being guided during every step of the process. Ordering 

Activities may focus less on managing the procurement process and more on the 

Ordering Activity’s core mission. GSA’s AAS includes highly experienced 

personnel with all stages of cloud acquisition. They can provide GSA Contracting 

Officer services for a fee. Contact AAS using their online form at aas.gsa.gov.

○ Office of Information Technology Category (ITC): connects federal, state, local, 

and tribal governments with the IT solutions and industry partners that can help 

them meet their missions. We support our ITC leadership team, led by Assistant 

Commissioner Laura Stanton. Learn more about ITC offerings through Laura's 

perspective in our Great Government through Technology blog. Our team helps 

harness the government's buying power to save agencies money on the cuttingedge technology they need to modernize. We lead initiatives to research 

emerging technologies that may help or impact the federal government's 

priorities and objectives and strive to build a loyal, satisfied customer base with 

best-in-class customer service.

Need help? To make sure we're delivering the quality service our agency and 

industry partners expect, we offer several support channels to help resolve 

questions and issues, improve acquisition efficiency, and identify the best IT 

solutions. Contact the IT Customer Service Center at ITCSC@gsa.gov or call us 

at 1-855-ITaid4U (1-855-482-4348).

○ Technology Transformation Services (TTS)

○ Cloud.gov: Cloud.gov is an 18F cloud PaaS product which enables 

Ordering Activities to deliver services to the public as fast as they can 

develop them. It is an open source, highly portable PaaS available to 

Ordering Activities. Ordering Activities may take the headache and 

confusion out of regulatory, compliance and security challenges by 

leveraging Cloud.gov’s FedRAMP Joint Authorization Board (JAB) 

Provisional Authority to Operate (P-ATO). Because it is built specifically 

for government by government, an authorized Ordering Activity can just 

manage its own code while Cloud.gov handles the security and 

maintenance of everything underneath. Cloud.gov is run on top of 

Amazon Web Services’ IaaS. For additional questions and Cloud.gov 

contact information, visit https://cloud.gov/docs/help/.

○ The Federal Risk and Authorization Management Program (FedRAMP): 

FedRAMP is a governmentwide program that provides a standardized 

approach to security assessment, authorization, and continuous 

monitoring for cloud products and services. It enables Ordering Activities 
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to rapidly adapt from old, insecure legacy IT to mission-enabling, secure, 

and cost effective cloud-based IT. 

All executive Ordering Activities are required to follow the FedRAMP 

process for any IaaS/PaaS/SaaS environment before putting it into 

production. Each Ordering Activity’s System Security Officer (SSO) is 

ultimately responsible for incorporating the FedRAMP process whenever 

cloud computing is involved. Contact the FedRAMP team by emailing 

info@FedRAMP.gov. 

○ Cloud Adoption Center of Excellence (CoE)

The Cloud Adoption CoE facilitates successful integration of cloud 

services by helping agencies select, and fashion, the right migration path 

to implement by an industry partner. The Cloud Adoption team developed 

a set of services based on best practices, both in the commercial and 

Government sectors, to help agencies successfully implement cloud 

strategies. Their service offerings include cloud security assessment, 

cloud governance implementation, cloud migration planning and more. 

The CoE posts updates on their work, best practices, progress and more 

here. 

Contact the Cloud Adoption Center of Excellence by emailing 

connectcoe@gsa.gov.

For additional help expressing cloud requirements and to access the various cloud templates for 

each migration stage, visit https://cic.gsa.gov/resources/templates or email cloudinfo@gsa.gov.

3. Governance

Without proper cloud governance in place, many funding, contracting, and general 

communication failures are likely. Without such governance/controls in place, your Ordering 

Activity could suffer runaway cloud expenses. 

In preparation for a cloud award, your Ordering Activity must be able to answer questions such 

as:

1. Who in the Ordering Activity will monitor the burn rate of the funding and be in charge of alerting 

others of issues of funding shortfall and/or overages?

2. Who will be the cloud finance point of contact that can reconcile cloud usage with a cloud 

invoice and review cloud utilization reports for chargeback purposes? Will it be the COR or 

someone else?

3. Who will have the task of provisioning new cloud services under a Task Order? Who will have 

the authority to delegate that task?

4. Who will be in charge of ensuring/authorizing the spinning down of cloud services when they are 

not in use?

5. Who will be responsible for monitoring security and compliance of the cloud services?
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The Ordering Activity might find that it needs to add a requirement for contractor labor to accomplish 

the above tasks. Even when contractor labor is not included in the solicitation, Ordering Activities must 

make it clear in their requirements that the CSP or authorized reseller must do nothing that restricts 

direct access to all tools, data, and capabilities that it requires for governance.

For an in depth review of governance, look at Section 8 of Federal Cloud Strategy Guide and the 

governance resources on the Cloud Information Center. 

GSA recommends coordinating with your CFO, OCAO, and legal counsel.

4. Fund the Acquisition

The proper funding of cloud computing contracts has been an obstacle to cloud services acquisition. As 

industry has innovated new ways to charge for cloud services on a consumption basis, federal 

procurement regulations have not kept pace. Cloud computing charges often accrue on a charge per 

use basis. Contracting Officers will need to work with the finance organization, OCAO, and legal 

counsel to determine what is the best “color of money” to use when funding a cloud contract for your 

Ordering Activity. 

Some points you may consider in your discussions:

● Funds will be obligated via Task Orders issued by an Ordering Contracting Officer for 

authorized Ordering Activities, in accordance with the ordering activity’s specific rules, 

regulations, policies and procedures.

The Ordering Activity Ordering Contracting Officer shall engage the Ordering Activity Financial 

Management Office and Program Management Office to ensure adequate and proper funds are 

available for Task Order placement.

● Capital Expenditure (CapEx) funds: (e.g., investment, procurement, or research and 

development funds) may sometimes be used to acquire and upgrade on premises (non-cloud) 

computer hardware and software for the longer term. Ordering activities must not circumvent 

appropriations regulations and use funds approved for CapEx to procure cloud services. Work 

with the finance organization, OCAO and legal counsel to determine if CapEx can be used and 

how far in advance they can be budgeted. 

● Operations Expenditure (OpEx) funds: (e.g., operations and maintenance or operations and 

sustainment funds) are used for more predictable, shorter term expenses. OpEx funds may be 

ideal for cloud, due to the month to month nature of cloud expenses. This is a natural transition 

from CapEx funding models as Ordering Activities decommission their data centers and begin 

using a cloud funding model with OpEx funds.

Congress annually distributes the year’s budgetary funds to appropriated Ordering Activities which are 

generally tied to one fiscal year. It is best practice to consult your Ordering Activities CFO, legal 

counsel, fiscal law experts, and contracting officer(s) to understand using no-year, multi-year, or 1 year 

funds and check (10 U.S.C 2306a and 41 U.S.C 3903) citations that might allow 1 year funds to fund 

multi-year FAR 17.1 contracts. Cloud services aren’t a one and done expense; rather something to 

refine, optimize, spin up and down, and leverage as you build out more of your cloud environment. 

Flexible working capital funds that span years have been found to work best, if your Ordering Activity 

has access to them.
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5. Issue a Solicitation

When market research and acquisition planning steps have been completed, and funding is secured, it 

is time to develop and publish a cloud solicitation. When the government wants to buy a good or 

service, it issues a solicitation. Solicitations are documents that make the government's requirements 

clear so that businesses can submit competitive bids.

a. eBuy:

In accordance with FAR 8.405-2, Ordering Activities may use GSA’s electronic RFQ system, called 

eBuy (the only electronic way to publish a solicitation against SIN 518210C) at no cost. Posting the 

RFQ on e-Buy allows all schedule contractors offering SIN 518210C an opportunity to submit a quote. 

GSA’s eBuy tool facilitates the process, all while keeping Ordering Activities FAR compliant. 

*Note that use of eBuy is not required in all circumstances and if ordering above the Simplified 

Acquisition Threshold (SAT), Ordering Activities need only “reasonably ensure that quotes will be 

received from at least three contractors that can fulfill the requirements” (see FAR 8.405-2(c)(3)(iii)(B)).

● Log onto ebuy.gsa.gov

● Select the contractors and/or GSA MAS SINs who your Ordering Activity want to receive the 

solicitation

● Release the solicitation to your selected contractors

Ordering activities can get assistance with eBuy via the Ordering Activity’s GSA National Account 

Manager (NAM), Customer Service Director (CSD) or their respective GSA MAS Contracting Officer 

(CO). If you need help getting connected with a GSA NAM/CSD or GSA MAS CO, email the GSA 

Cloud Team at cloudinfo@gsa.gov.

b. SAM.gov:

The System for Award Management, or SAM, is a government-wide portal that consolidates the 

capabilities of multiple systems and information sources used by the Federal government in conducting 

the acquisition and financial assistance. Anyone interested in doing business with the government can 

use this system to search opportunities. Opportunities include pre-solicitation notices, solicitation 

notices, award notices, and sole source notices.

6. Evaluation of Responses

There are multiple technical metrics to consider when evaluating the different cloud service offerings 

submitted in offeror/contractor quotes: performance, security, and agility, to name a few. Proposed 

individual cloud UPCs are difficult to compare on a one-to-one basis. Thus, many Ordering Activities 

have used the best value method to trade off one metric for another. By providing a selection, Ordering 

Activities are afforded the opportunity to fulfill their requirements with the offerings that constitute the 

best value and that meet their needs at the lowest overall cost. 

Example metrics to consider for IaaS/PaaS cloud service offerings:
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● Security

○ General Services Administration (GSA), Federal Risk and Authorization 

Management Program (FedRAMP) Impact Level (IL) Moderate Authorization 

○ Department of Defense Cloud Computing Security Requirements Guide (SRG) 

Impact Level (IL) 2 Authorization 

○ Cybersecurity Maturity Model Certification (CMMC) (e.g., Level 2) or Third-Party

Cybersecurity Audit of Computer Systems and Practices 

○ Supply Chain Risk Management (SCRM) Plan 

○ Participation and operational compatibility in Government cybersecurity 

monitoring and reporting programs (e.g., Department of Homeland Security 

(DHS) Continuous Diagnostic and Mitigation (CDM) Program).

● Technical

○ Availability and Reliability

○ Services aligning with and facilitating Zero Trust Architecture (ZTA)

● Operational 

○ On-Demand Self-Service interface that allows end users (e.g., Government) to 

independently operate (e.g., start, suspend, terminate), manage (e.g., budget, 

schedule, scale), and monitor (e.g., utilization, performance, costs, users) 

services 

○ Measured Services that allow for pay-as-you-go, pay-per-use, or charge-per-use 

for services.

It is important to note, the evaluation process MUST align with the technical evaluation factors specified 

in the solicitation.

7. Make an Award

GSA’s Acquisition Letter (AL) MV-21-06, Procurement of Cloud Computing on a Consumption 

Basis under the Federal Supply Schedule (FSS) program and Supplement 1, dated March 18, 

2022, establishes special ordering procedures for the procurement of cloud computing on a 

consumption basis for the Federal Supply Schedule program. As a result of this AL, GSAR 

Clause 552.238-199 Special Ordering Procedures Applicable when Procuring Cloud 

Computing on a Consumption Basis (MAR 2022) should be included in the awarded 

BPA/Task Order (See Appendix A). This will add a requirement that will give the authorized 

Ordering Activity access to commercial sale pricelist tools to help in accomplishing the above 

tasks. 
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Appendix A: GSAR Clause 552.238-199

[GSAR Clause 552.238-199 Special Ordering Procedures Applicable when Procuring 

Cloud Computing on a Consumption Basis 

As directed by Acquisition Letter MV-21-06, GSA FSS Contracting Officers shall insert the 

following clause in contracts offering cloud computing services on a consumption basis under 

Special Item Number (SIN) 518210C (previously 132-40) or successor SINs within the 

Information Technology (IT) Category (previously Schedule 70): 

SPECIAL ORDERING PROCEDURES APPLICABLE WHEN PROCURING CLOUD

COMPUTING ON A CONSUMPTION BASIS (MAR 2022)

(a) Definitions.

(1) “Capital asset” has the meaning given the term by Office of Management and Budget 

(OMB) Circular A-11 Capital Programming Guide and any amendatory or superseding 

document(s) thereto. 

(2) “Cloud computing” has the meaning given the term by the National Institute of 

Standards and Technology in Special Publication (SP) 800–145 and any amendatory or 

superseding document(s) thereto.

(3) “Consumption basis” or “consumption-based” means any offering that

is metered with charges that accrue on a predetermined periodic basis (e.g., per

second, minute, hour, week, month, or another per-unit basis) and is billed based

on actual usage during an elapsed period with predetermined pricing or

discounts.

(4) “Requirements task order” means a task order that provides for filling

all actual purchase requirements of a designated Ordering Activity during a

specified contract period, with performance by the contractor being scheduled

when the Ordering Activity awards, or exercises options for, individual contract

line items (CLINs) under the task order.

(i) This task order type is appropriate when the Ordering Activity

anticipates recurring requirements but cannot predetermine the precise

quantities of services that it will need during a definite period.

(ii) A requirements task order issued under a FSS contract is a single

contract award as defined FAR 2.101. Individual CLINs executed and funded

under this task order type are not considered to be second-tier instruments

issued under the awarded task order.

(iii) A requirements task order is not a requirements contract as

described at FAR 16.503.

(b) Ordering procedures.
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(1) FAR 8.403(b) provides that GSA may establish special ordering

procedures for a particular FSS offering.

(2) The procedures in FAR subpart 8.4 apply to this contract, with the

exceptions listed in this clause. If a requirement in this clause is inconsistent with

FAR subpart 8.4, this clause takes precedence pursuant to FAR 8.403(b).

(c) Applicability.

(1) The Ordering Activity Contracting Officer shall follow the procedures

contained within this clause when placing an incrementally funded task order

under this contract for cloud computing services on a consumption basis.

(2) The Ordering Activity Contracting Officer is permitted, but not required

to, use the procedures contained within this clause for task orders that are not

incrementally funded.

(3) The Ordering Activity Contracting Officer shall not use the procedures

contained within this clause for the acquisition, maintenance, or modification of

capital assets.

(d) Pricing.

(1) The Ordering Activity Contracting Officer shall establish a task order

ceiling price for all estimated requirements.

(2) All cloud computing services offered under this FSS contract are

considered fixed-price.

(e) Task order type. The Ordering Activity Contracting Officer shall use a

requirements task order for cloud computing services procured on a

consumption basis in accordance with this clause.

(1) This task order type may include other contract types, such as

firm-fixed-price, when procuring other offerings under this contract that are not

being procured on a consumption-basis.

(2) Estimates for cloud computing services to be procured on a

consumption basis.

(i) The Ordering Activity Contracting Officer must state a realistic

estimate of—

(A) The consumption of cloud computing services in the task order

solicitation; and

(B) The total amount in dollars to be expended on cloud

consumption in the task order.

(ii) This estimate is not a representation to an Offeror or Contractor that
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the estimated consumption will be required or ordered, or that conditions

affecting requirements will be stable or normal.

(iii) The Ordering Activity Contracting Officer may obtain the estimate

from records of previous requirements and consumption, or by other means, and

should base the estimate on the most current information available.

(iv) If the Government’s requirements do not meet this estimate, that fact shall 

not constitute the basis for an equitable price adjustment.

(3) All CLINs within the task order must include a defined scope with all

services priced at the time of award.

(f) Incremental funding.

(1) The Ordering Activity may allot funds incrementally as the bona fide

need arises for predefined and established fixed-priced procurement

requirements on individual CLINs.

(2) The Ordering Activity shall ensure sufficient funds are allotted to the

task order—

(i) At the time of award to cover the total amount payable to the

Contractor for the awarded CLIN(s); and

(ii) At the time an optional CLIN is exercised to cover the total amount

payable to the Contractor for that optional CLIN.

(3) Nothing in this clause shall be construed to supersede the Ordering

Activity’s contract funding policies.

(g) Consumption monitoring.

(1) The Contractor shall—

(i) Provide, at no additional cost to the Government, access to tools that

enable the Government to track its usage of cloud computing services offered on

a consumption basis; or

(ii) Notify the Ordering Activity Contracting Officer when total

consumption reaches—

(A) 50 percent and 75 percent of the ceiling price for each CLIN for

consumption-based cloud computing services, or other milestones as 

agreed

upon by the Contractor and the Ordering Activity Contracting Officer; and

(B) 50 percent and 75 percent of the task order ceiling price, or other

milestones as agreed upon by the Contractor and the Ordering Activity

Contracting Officer.
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(2) The Ordering Activity Contracting Officer shall determine that the consumption 

monitoring capabilities offered by the Contractor will enable the Government to 

adequately track its incurred costs before awarding a task order in accordance with this 

clause. 

(h) Limitation of funds.

(1) The Government will not be obligated to pay the Contractor any amount

in excess of the ceiling price in the task order, and the Contractor shall not be

obligated to continue performance if doing so would exceed the ceiling price set

forth in the task order.

(2) The Ordering Activity Contracting Officer may use a Limitation of Funds

clause when CLINs under the task order are incrementally funded.

(i) Scope reviews.

(1) The Ordering Activity Contracting Officer is encouraged to request a

scope review from the GSA Federal Acquisition Service (FAS) Office of

Information Technology Category (ITC) before placing a task order in accordance

with these special ordering procedures.

(2) The purpose of a scope review is to analyze whether the planned

acquisition is—

(i) compatible with the scope of Special Item Number (SIN) 518210C

(previously 132-40) or successor SINs;

(ii) utilizing recommended best practices; and

(iii) not for the acquisition, maintenance, or modification of capital

Assets.

(3) The Ordering Activity Contracting Officer may request a scope review by contacting 

FAS ITC at cloud-sin-rfi@gsa.gov. 

(End of clause)]
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Appendix B: Examples of Consumption Based 

Ordering

CSP cloud service catalogs are changing quickly and constantly and many Ordering Activities 

want to take advantage of any new emerging technology as soon as it is available. An Ordering 

Activity may need an authorized contractor to have the new service(s) added to their GSA MAS 

Service Catalog if they aren’t listed as an awarded CLIN. For currently awarded TO’s, the CO 

will need to negotiate with the authorized contractor before modifying the TO to add the new 

services and pricing. 

Below are examples of the implementation of a CLIN structure for the acquisition of cloud 

compute (i.e., IaaS) services based on the addition of GSAR Clause 552.238-199 Special 

Ordering Procedures Applicable when Procuring Cloud Computing on a Consumption Basis into 

the MAS Solicitation. The examples and analysis are not exhaustive and are meant to give an 

Ordering Activity only the guidance of what’s possible.

1. Fixed Price Non-Term Cloud Computing Services (e.g., On-Demand)

○ Awarded CLINs:

■ have a defined scope (e.g., functional, technical) and are fully funded at 

time of award with funded values being the ceiling value of the CLIN.

■ Examples below in Figures 1-3: (CLINs 1000, 2000)

■ Sub-CLINs - Under the Awarded CLINs there are Sub-CLINs with 

explicitly defined scope (i.e., explicit compute type) that falls within the 

scope of the Awarded CLIN.

■ The Sub-CLINs are not individually funded at time of award, all funding 

remains obligated at the Awarded CLIN level. 

■ The Sub-CLINs with the explicitly defined scope lists the specific compute 

service (i.e., “cloud reservation” type) with negotiated and awarded unit 

cost and the unit of measure. The quantity is left empty at time of award.

■ As the Ordering Activity uses the listed Sub-CLINs compute services the 

Ordering Activity is invoiced in arrears on a monthly basis. The invoice 

lists the quantity of services used for each Sub-CLIN and provides an 

incurred cost for each explicit service. The total incurred costs for all SubCLINs is then subtracted from the Award CLIN resulting in the balance of 

funding (i.e., remaining funding on the CLIN).

■ Under this model the Ordering Activity has documented what cloud 

services have been awarded (i.e., on contract) and the awarded price per 

listed unit of measure for that service (i.e., Fixed Price). This then allows 

consumed (i.e., used) services to be traceable at time of invoice. The 

Ordering Activity’s usage is cumulative month to month and each invoice 
Guidance & Not Legal Authority

28

will list the cumulative usage (i.e., quantity) for each Sub-CLIN.

○ Optional CLINs - Not funded at time of award. The OACO has to execute a 

contract modification to execute and fully fund the Optional CLIN. 

■ Optional CLINs allow the OACO to incrementally fund services by 

executing and fully funding each optional CLIN as funds are expensed. 

This limits the risk that a significant amount of funding will remain on the 

contract at the end of a period of performance and require de-obligation 

contacting actions where the de-obligated funding may not be available 

for re-obligation to another CLIN or contract (e.g., 1 Year funds).

■ Examples below in Figures 1-3: (CLIN 2100)

■ Sub-CLINs - The same logic for an awarded CLINs Sub-CLIN above 

applies here. 

■ In the example below the OCO executes the optional CLIN sometime in 

October when the OACO is notified that CLIN 2000 is 50% or 75% 

expended (i.e., costs incurred). 

■ When the OACO executes the optional CLIN 2100, that is a duplication of 

CLIN 2000, there is no disruption in services when CLIN 2000 is fully 

expended. The ongoing incurred costs simply transition to CLIN 2100 

without interruption.

Example A: Non-Term (On-Demand) Cloud Compute

In Figures 1-3 below, there are 3 monthly invoices for 2 awarded CLINs and 1 optional 

CLIN. The yellow filled cells in Figure 2 indicate quantity changes between the 

September and October invoices (i.e., October usage), and the orange fill in Figure 3 

indicate the quantity changes between October and November (i.e., November usage). 

From September to November the awarded CLINs balances decreased to indicate the 

Ordering Activities continued usage of services.

[Figure 1] September Invoice (awarded CLINs being utilized. Optional CLIN remains 

unfunded).

CLIN Type CLIN 

Number

CLIN Scope Unit Cost Unit of 

Measure

Quantity Incurred 

Cost

Awarded Sub-CLIN 1001 a1.medium $0.0255 Compute / Hr 100 $2.55

Awarded Sub-CLIN 1002 a1.large $0.0510 Compute / Hr 50 $2.55

Awarded Sub-CLIN 1003 a1.xlarge $0.1020 Compute / Hr 23 $2.35

Awarded Sub-CLIN 1004 a1.2xlarge $0.2040 Compute / Hr 1000 $204.00

Awarded Sub-CLIN 1005 a1.4xlarge $0.4080 Compute / Hr 5004 $2,041.63

Awarded Sub-CLIN 2001 p3.2xlarge $3.0600 Compute / Hr 2500 $7,650.00

Awarded Sub-CLIN 2002 p3.8xlarge $12.2400 Compute / Hr 567 $6,940.08

Awarded Sub-CLIN 2003 p3.16xlarge $24.4800 Compute / Hr 354 $8,665.92
Guidance & Not Legal Authority

29

CLIN Type CLIN 

Number

CLIN Scope Unit Cost Unit of 

Measure

Quantity Incurred 

Cost

Optional Sub-CLIN 2101 p3.2xlarge $3.0600 Compute / Hr 0 $0.00

Optional Sub-CLIN 2102 p3.8xlarge $12.2400 Compute / Hr 0 $0.00

Optional Sub-CLIN 2103 p3.16xlarge $24.4800 Compute / Hr 0 $0.00

End of Month Balances at the parent CLIN level for Figure 1.

CLIN Type CLIN Number CLIN Scope Funded Balance

Awarded CLIN 1000 General Compute $100,000.00 $97,746.92

Awarded CLIN 2000 Accelerated Computing $50,000.00 $26,744.00

Optional CLIN 2100 Accelerated Computing $0.00 $0.00

[Figure 2] October Invoice (awarded CLINs continue to draw down on funded ceiling. 

Optional CLIN remains unfunded but may be activated by OACO as the consumption of 

CLIN 2000 hit 50% of the ceiling price)

CLIN Type CLIN 

Number

CLIN 

Scope

Unit Cost Unit of 

Measure

Quantity Incurred 

Cost

Awarded Sub-CLIN 1001 a1.medium $0.0255 Compute / Hr 100 $2.55

Awarded Sub-CLIN 1002 a1.large $0.0510 Compute / Hr 50 $2.55

Awarded Sub-CLIN 1003 a1.xlarge $0.1020 Compute / Hr 23 $2.35

Awarded Sub-CLIN 1004 a1.2xlarge $0.2040 Compute / Hr 1000 $204.00

Awarded Sub-CLIN 1005 a1.4xlarge $0.4080 Compute / Hr 11004 $4,489.63

Awarded Sub-CLIN 2001 p3.2xlarge $3.0600 Compute / Hr 5265 $16,110.90

Awarded Sub-CLIN 2002 p3.8xlarge $12.2400 Compute / Hr 567 $6,940.08

Awarded Sub-CLIN 2003 p3.16xlarge $24.4800 Compute / Hr 354 $8,665.92

Optional Sub-CLIN 2101 p3.2xlarge $3.0600 Compute / Hr 0 $0.00

Optional Sub-CLIN 2102 p3.8xlarge $12.2400 Compute / Hr 0 $0.00

Optional Sub-CLIN 2103 p3.16xlarge $24.4800 Compute / Hr 0 $0.00

End of Month Balances at the parent CLIN level for Figure 2.

CLIN Type CLIN 

Number

CLIN Scope Funded Balance

Awarded CLIN 1000 General Compute $100,000.00 $95,298.92

Awarded CLIN 2000 Accelerated Computing $50,000.00 $18,283.10

Optional CLIN 2100 Accelerated Computing $0.00 $0.00
Guidance & Not Legal Authority

30

[Figure 3] November Invoice (awarded CLINs continue to draw down on the funded 

ceiling. Optional CLIN 2100 has been activated and funded).

CLIN Type CLIN 

Number

CLIN 

Scope

Unit Cost Unit of

Measure

Quantity Incurred 

Cost

Awarded Sub-CLIN 1001 a1.medium $0.0255 Compute / Hr 110 $2.81

Awarded Sub-CLIN 1002 a1.large $0.0510 Compute / Hr 50 $2.55

Awarded Sub-CLIN 1003 a1.xlarge $0.1020 Compute / Hr 23 $2.35

Awarded Sub-CLIN 1004 a1.2xlarge $0.2040 Compute / Hr 1000 $204.00

Awarded Sub-CLIN 1005 a1.4xlarge $0.4080 Compute / Hr 26004 $10,609.63

Awarded Sub-CLIN 2001 p3.2xlarge $3.0600 Compute / Hr 11239 $34,391.34

Awarded Sub-CLIN 2002 p3.8xlarge $12.2400 Compute / Hr 567 $6,940.08

Awarded Sub-CLIN 2003 p3.16xlarge $24.4800 Compute / Hr 354 $8,665.92

Optional Sub-CLIN 2101 p3.2xlarge $3.0600 Compute / Hr 2456 $7,515.36

Optional Sub-CLIN 2102 p3.8xlarge $12.2400 Compute / Hr 0 $0.00

Optional Sub-CLIN 2103 p3.16xlarge $24.4800 Compute / Hr 0 $0.00

End of Month Balances at the parent CLIN level for Figure 3.

CLIN Type CLIN 

Number

CLIN Scope Funded Balance

Awarded CLIN 1000 General Compute $100,000.00 $89,178.67

Awarded CLIN 2000 Accelerated Computing $50,000.00 $2.66

Optional CLIN 2100 Accelerated Computing $50,000.00 $42,484.64

2. Fixed Price (FP) - Term Cloud Computing Services (e.g., “cloud reservations”)

○ Awarded CLINs - Under the (FP) Term Cloud Computing Services (e.g., “cloud 

reservations”) there are only Awarded CLINs. 

○ Optional CLINs - Not permitted. 

Cloud reservations - are defined by 3 parameters: Service, Cost, and Term Period. The 

Ordering Activity is locked into a set cost for a defined service regardless of whether or 

not the Ordering Activity uses the service. 

As a result, only an OCO can execute/activate these services since only a warranted 

Contracting Officer can enter into, administer, and/or terminate contracts within the limits 

of their authority.

Example B: Term (“cloud reservations”) Cloud Compute (IaaS)

CLINs are fully funded at time of execution and should be invoiced monthly or in 

accordance with the payment terms for the cloud reservations. 
Guidance & Not Legal Authority

31

In this example the contract was awarded in September making August the 12 months. 

For CLINs 4000 - 4004 the 1 year Term Cloud Computing Services have been fully 

expended and the balance is $0.00.

FFP CLINs should be used for Ordering Activity baseline (e.g., steady state) cloud 

services in order to maximize cost savings.

[Figure 1] September Invoice (incurred cost increases as balance decreases steadily over 

time).

CLIN 

Type

CLIN 

Number

CLIN 

Scope

Unit Cost Unit of 

Measure

Quantity Incurred 

Cost

Funded Balance

Awarded 

CLIN

4000 General 

Compute -

a1.medium

$11.7500 RI 

Monthly 

Fee (1-

Year)

1 $11.75 $141.00 $129.25

Awarded 

CLIN

4001 General 

Compute -

a1.large

$23.4300 RI 

Monthly 

Fee (1-

Year)

1 $23.43 $281.16 $257.73

Awarded 

CLIN

4002 General 

Compute -

a1.xlarge

$46.9400 RI 

Monthly 

Fee (1-

Year)

1 $46.94 $563.28 $516.34

Awarded 

CLIN

4003 General 

Compute -

a1.2xlarge

$93.8100 RI 

Monthly 

Fee (1-

Year)

1 $93.81 $1,125.72 $1,031.91

Awarded 

CLIN

4004 General 

Compute -

a1.4xlarge

$187.6100 RI 

Monthly 

Fee (1-

Year)

1 $187.61 $2,251.32 $2,063.71

Awarded 

CLIN*

5000 General 

Compute -

a1.medium

$8.0300 RI 

Monthly 

Fee (3-

Year)

1 $8.03 $289.08 $281.05

Awarded 

CLIN*

5001 General 

Compute -

a1.large

$16.0600 RI 

Monthly 

Fee (3-

Year)

1 $16.06 $578.16 $562.10

Awarded 

CLIN*

5002 General 

Compute -

a1.xlarge

$32.1900 RI 

Monthly 

Fee (3-

Year)

1 $32.19 $1,158.84 $1,126.65

Awarded 

CLIN*

5003 General 

Compute -

a1.2xlarge

$64.3100 RI 

Monthly 

Fee (3-

Year)

1 $64.31 $2,315.16 $2,250.85

Awarded 

CLIN*

5004 General 

Compute -

a1.4xlarge

$128.7000 RI 

Monthly 

Fee (3-

Year)

1 $128.70 $4,633.20 $4,504.50
Guidance & Not Legal Authority

32

[Figures 2-3] October-November Invoices (incurred cost increases as balance decreases 

steadily over time).

October Invoice 

CLIN 

Type

CLIN 

Number

CLIN 

Scope

Unit Cost Unit of 

Measure

Quantity Incurred 

Cost

Funded Balance

Awarded 

CLIN

4000 General 

Compute -

a1.medium

$11.7500 RI Monthly 

Fee (1-

Year)

1 $23.5000 $141.00 $117.50

Awarded 

CLIN

4001 General 

Compute -

a1.large

$23.4300 RI Monthly 

Fee (1-

Year)

1 $46.8600 $281.16 $234.30

Awarded 

CLIN

4002 General 

Compute -

a1.xlarge

$46.9400 RI Monthly 

Fee (1-

Year)

1 $93.8800 $563.28 $469.40

Awarded 

CLIN

4003 General 

Compute -

a1.2xlarge

$93.8100 RI Monthly 

Fee (1-

Year)

1 $187.6200 $1,125.72 $938.10

Awarded 

CLIN

4004 General 

Compute -

a1.4xlarge

$187.6100 RI Monthly 

Fee (1-

Year)

1 $375.2200 $2,251.32 $1,876.10

Awarded 

CLIN*

5000 General 

Compute -

a1.medium

$8.0300 RI Monthly 

Fee (3-

Year)

1 $16.0600 $289.08 $273.02

Awarded 

CLIN*

5001 General 

Compute -

a1.large

$16.0600 RI Monthly 

Fee (3-

Year)

1 $32.1200 $578.16 $546.04

Awarded 

CLIN*

5002 General 

Compute -

a1.xlarge

$32.1900 RI Monthly 

Fee (3-

Year)

1 $64.3800 $1,158.84 $1,094.46

Awarded 

CLIN*

5003 General 

Compute -

a1.2xlarge

$64.3100 RI Monthly 

Fee (3-

Year)

1 $128.6200 $2,315.16 $2,186.54

Awarded 

CLIN*

5004 General 

Compute -

a1.4xlarge

$128.7000 RI Monthly 

Fee (3-

Year)

1 $257.4000 $4,633.20 $4,375.80

November Invoice

CLIN 

Type

CLIN 

Number

CLIN Scope Unit Cost Unit of 

Measure

Quantity Incurred 

Cost

Funded Balance

Awarded 

CLIN

4000 General 

Compute -

a1.medium

$11.7500 RI 

Monthly 

Fee (1-

Year)

1 $35.2500 $141.00 $105.75

Awarded 

CLIN

4001 General 

Compute -

a1.large

$23.4300 RI 

Monthly 

Fee (1-

Year)

1 $70.2900 $281.16 $210.87

Awarded 

CLIN

4002 General 

Compute -

a1.xlarge

$46.9400 RI 

Monthly 

Fee (1-

Year)

1 $140.8200 $563.28 $422.46
Guidance & Not Legal Authority

33

CLIN 

Type

CLIN 

Number

CLIN Scope Unit Cost Unit of 

Measure

Quantity Incurred 

Cost

Funded Balance

Awarded 

CLIN

4003 General 

Compute -

a1.2xlarge

$93.8100 RI 

Monthly 

Fee (1-

Year)

1 $281.4300 $1,125.72 $844.29

Awarded 

CLIN

4004 General 

Compute -

a1.4xlarge

$187.6100 RI 

Monthly 

Fee (1-

Year)

1 $562.8300 $2,251.32 $1,688.49

Awarded 

CLIN*

5000 General 

Compute -

a1.medium

$8.0300 RI 

Monthly 

Fee (3-

Year)

1 $24.0900 $289.08 $264.99

Awarded 

CLIN*

5001 General 

Compute -

a1.large

$16.0600 RI 

Monthly 

Fee (3-

Year)

1 $48.1800 $578.16 $529.98

Awarded 

CLIN*

5002 General 

Compute -

a1.xlarge

$32.1900 RI 

Monthly 

Fee (3-

Year)

1 $96.5700 $1,158.84 $1,062.27

Awarded 

CLIN*

5003 General 

Compute -

a1.2xlarge

$64.3100 RI 

Monthly 

Fee (3-

Year)

1 $192.9300 $2,315.16 $2,122.23

Awarded 

CLIN*

5004 General 

Compute -

a1.4xlarge

$128.7000 RI 

Monthly 

Fee (3-

Year)

1 $386.1000 $4,633.20 $4,247.10

[Figure 4] August Invoice (at month 12) (incurred cost has reached funded amount and 

balance is 0.00 for 1-Year) (3-Year is at 1/3 spent).

CLIN 

Type

CLIN 

Number

CLIN 

Scope

Unit Cost Unit of 

Measure

Quantity Incurred 

Cost

Funded Balance

Awarded 

CLIN

4000 General 

Compute -

a1.medium

$11.7500 RI 

Monthly 

Fee (1-

Year)

1 $141.0000 $141.00 $0.00

Awarded 

CLIN

4001 General 

Compute -

a1.large

$23.4300 RI 

Monthly 

Fee (1-

Year)

1 $281.1600 $281.16 $0.00

Awarded 

CLIN

4002 General 

Compute -

a1.xlarge

$46.9400 RI 

Monthly 

Fee (1-

Year)

1 $563.2800 $563.28 $0.00

Awarded 

CLIN

4003 General 

Compute -

a1.2xlarge

$93.8100 RI 

Monthly 

Fee (1-

Year)

1 $1,125.7200 $1,125.72 $0.00
Guidance & Not Legal Authority

34

CLIN 

Type

CLIN 

Number

CLIN 

Scope

Unit Cost Unit of 

Measure

Quantity Incurred 

Cost

Funded Balance

Awarded 

CLIN

4004 General 

Compute -

a1.4xlarge

$187.6100 RI 

Monthly 

Fee (1-

Year)

1 $2,251.3200 $2,251.32 $0.00

Awarded 

CLIN*

5000 General 

Compute -

a1.medium

$8.0300 RI 

Monthly 

Fee (3-

Year)

1 $96.3600 $289.08 $192.72

Awarded 

CLIN*

5001 General 

Compute -

a1.large

$16.0600 RI 

Monthly 

Fee (3-

Year)

1 $192.7200 $578.16 $385.44

Awarded 

CLIN*

5002 General 

Compute -

a1.xlarge

$32.1900 RI 

Monthly 

Fee (3-

Year)

1 $386.2800 $1,158.84 $772.56

Awarded 

CLIN*

5003 General 

Compute -

a1.2xlarge

$64.3100 RI 

Monthly 

Fee (3-

Year)

1 $771.7200 $2,315.16 $1,543.44

Awarded 

CLIN*

5004 General 

Compute -

a1.4xlarge

$128.7000 RI 

Monthly 

Fee (3-

Year)

1 $1,544.4000 $4,633.20 $3,088.80

* Allowable only under Multiple Year Contracts (FAR 17.1) where the Period of Perfromance (PoP) is 3 

years or longer.

Other Notes when dealing with CLINs and Authorized Contractors:

● “Broad” all encompassing CLINs - In regard to Line Items, FAR 8-404(j) "Line Items'' 

states, “When placing orders or establishing BPAs, ordering activities shall reference the 

special item number and the corresponding line or subline item awarded (established 

per 4.1005) in the schedule.” So, the FAR requires that the Line Item on the Ordering 

Activity’s Task/Purchase Order references the line or subline on the Contractor’s GSA 

Schedule Pricelist. Unless the GSA Schedule Pricelist has awarded a specific line-item 

price for a “catalog of available cloud services”,i.e.., "Broad CLIN", the Ordering Activity 

may not be able to award an Order for a “Broad CLIN.” The Order would need to list the 

specific CLINs awarded by the Ordering Activity that map to specific items listed on the 

awarded GSA Schedule Pricelist.

● “Cloud Marketplaces” - This is a selection of offerings that may support the workload and 

cloud requirements of an Ordering Activity. If using, the Ordering Activity needs to 

ensure the Line Item they are enabling from the marketplace is in the original 

requirements. Just because you have the ability to go to a CSP and “turn on” new 

financial management or HR type software with just a click, doesn’t mean it is within 

scope of your original stated contract requirements.