Price increases under a GSA contract fail more often than they are approved. Not because the math is wrong. Because the trigger is wrong, the timing is wrong, or the contractor misunderstands what GSA is actually permitting.
In 2026, GSA continues to reject Economic Price Adjustment requests that rely on commercial logic instead of contract logic. Inflation alone is not a basis. Market pressure is not a basis. Internal cost increases are rarely sufficient on their own.
Once a GSA Economic Price Adjustment is denied, the exposure compounds. Pricing files are flagged. Future modifications receive additional review. In some cases, contracting officers revisit the original Most Favored Customer disclosures. That is where risk escalates.
How to raise GSA prices depends on the Economic Price Adjustment clause tied to your contract. Only specific clauses allow increases, only under defined conditions, and only with supporting documentation that aligns to the awarded pricing basis. Outside those boundaries, price increases are not permitted.
Understanding GSA EPA Without Assuming Flexibility
A GSA Economic Price Adjustment (EPA) is not a general permission to increase prices. It is a limited contractual mechanism governed by the clause incorporated at award.
Most GSA Schedule contracts rely on one of three EPA structures:
- EPA tied to a commercial price list or catalog
- EPA tied to a market indicator such as CPI
- EPA based on negotiated fixed escalation caps
Each structure carries different thresholds, notice requirements, and documentation standards. Contractors often assume these are interchangeable. They are not.
The General Services Administration evaluates EPA requests against the awarded clause language, not against current economic conditions.
When GSA Allows Price Increases and When It Does Not
EPA Based on Commercial Price Lists
If your contract is awarded under a commercial price list basis, price increases may be permitted only after:
- The commercial price list has formally increased
- The increase is applied consistently to the Most Favored Customer class
- The revised pricing maintains the negotiated GSA discount relationship
Unilateral increases, internal cost adjustments, or selective price list updates trigger denials. GSA expects symmetry between the commercial market and the Schedule.
EPA Based on Market Indicators
Contracts tied to CPI or other indices are bound by:
- The specific index named in the clause
- The adjustment frequency stated in the contract
- Any ceiling or cap negotiated at award
Applying the wrong CPI series or miscalculating the adjustment period is a common failure point. GSA reviews these submissions mechanically.
EPA With Fixed Escalation Caps
Some contracts allow predetermined annual increases. These do not require justification beyond the passage of time, but:
- Increases exceeding the cap are not allowed
- Missed escalation windows cannot be retroactively recovered
- Applying the increase late can forfeit it entirely
Timing errors here are permanent.
Incorrect Assumptions That Cause EPA Rejections
Contractors often submit EPA requests believing:
- Inflation automatically justifies higher GSA pricing
- Commercial customers can be treated differently than GSA
- Partial documentation is acceptable if the increase is modest
- Prior approvals guarantee future approvals
None of these assumptions hold. GSA evaluates each EPA independently and retains discretion to reopen pricing relationships if inconsistencies appear.
The Correct Way to Approach a GSA Price Increase
Effective EPA submissions follow sequence, not urgency.
First, confirm which EPA clause governs the SINs affected. Many contracts contain multiple pricing bases across SINs. Submitting one EPA across incompatible structures leads to blanket denial.
Second, validate the pricing basis against current commercial practices. If your commercial discounting has drifted since award, an EPA request can expose that drift.
Third, assemble documentation that mirrors the contract language exactly. GSA reviewers are not reconciling intent. They are validating compliance.
Finally, submit only when eligibility is clear. A denied EPA remains in the contract file.
Prior Denials, Contract Risk, and Reapplication Exposure
If your contract has prior EPA denials, the risk profile changes. Contracting officers may:
- Require additional substantiation on future modifications
- Question the integrity of commercial sales practices
- Delay unrelated contract actions
In extreme cases, repeated improper EPA attempts contribute to broader compliance reviews. There is no formal limit, but the pattern matters.
Where Capitol 50 Fits in the Decision Process
Capitol 50 reviews EPA eligibility before submission, not after denial. The focus is clause alignment, pricing exposure, and documentation sufficiency. The goal is not approval at any cost. It is preventing unnecessary contract risk.
For contractors evaluating how to raise GSA prices in 2026, the responsible step is confirming whether an increase is permitted at all under the awarded structure. That determination often precedes whether an EPA should be attempted.
Contract holders unsure whether their pricing basis still supports an increase typically begin with a pricing and compliance review. Capitol 50’s assessment process is designed to identify whether an EPA submission will withstand scrutiny or introduce exposure. That review is often the difference between a clean modification and a permanent flag in the contract file.
A structured eligibility check can be requested through Capitol 50’s contract review process here:
https://Cap50.com/contract-qualification-review/
