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10/23/2020

TDR - How Contractors Can Avoid the GSA Price Reductions Clause

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GSA Transactional Data Reporting TDR Avoids Price Reduction Clause PRCTransactional Data Reporting (TDR) was officially introduced in August of 2016 as a three-year pilot program under eight GSA Schedules. For contractors, TDR provides the option of holding a GSA Contract without the burden of the infamous Price Reductions Clause (PRC). For GSA, TDR provides critical insight into what the federal government is buying to help fuel smarter purchasing.

What is Transactional Data Reporting?

TDR was created to support Category Management, which is a government-wide initiative to approach federal buying as a single enterprise. Transactional level data on federal purchases provides the government with market intelligence to make smarter acquisitions and achieve taxpayer savings, which are key Category Management goals. With that in mind, companies that participate in TDR are required to report specific data, including the price paid by federal buyers for products and services purchased through the company’s GSA Contract.

If You Participate in TDR, What Data Do You Have to Submit?

  • Contract/BPA Number
  • SIN Number
  • Order Number or Procurement Instrument Identifier (PIID)
  • Description of Deliverable
  • Manufacturer Name (for products)
  • Manufacturer Part Number (for products)
  • Unit of Measure (each, hour, case, lot, etc.)
  • Quantity of Item Sold
  • Universal Product Code (UPC) if applicable
  • Price Paid per Unit
  • Total Paid Price
  • Non-Federal Entity, if applicable

What are the Pros & Cons of TDR?

There are some trade-offs made in participating in TDR. In addition to reporting all of the data points detailed above, companies are required to report more frequently — on a monthly basis instead of a quarterly basis. However, companies still have the option to remit IFF on a quarterly basis. While some companies have been apprehensive of the additional reporting requirements, many have found them to be less cumbersome than anticipated. In exchange for the detailed monthly reporting, companies are exempt from the traditional GSA Contract requirements detailed below — which equates to a substantial benefit.

Contracts Participating in TDR Are NOT Required to:

  • Disclose Commercial Sales Practices
  • Establish a Most Favored Customer (MFC)/Basis of Award (BOA)
  • Track and Maintain the Relationship Between GSA Pricing and BOA/MFC Customer Pricing
  • Comply With the Price Reductions Clause, Which May Require a Reduction in GSA Pricing if Pricing is Discounted Commercially or to a Company’s BOA/MFC

Who Can Participate in TDR?
TDR Eligible GSA SINs

If your company offers products or services under any of the GSA Special Item Numbers (SINs) listed in the chart below, you have the option to participate in TDR.

Notes on TDR Participation:

  • TDR participation is optional
  • Once you make a decision regarding participation in TDR, you may not reverse that decision
  • If you hold or are pursuing a GSA Contract with multiple SINs and just one SIN is TDR eligible, you have the option to participate in TDR
  • If you participate in TDR, it applies to your entire GSA Contract, not just the SIN that is TDR eligible

What’s Next for the TDR Program?

Will TDR become a permanent option for GSA contractors? Will GSA extend TDR to the entire MAS Contract, or will it continue to only be available under select SINs?

Last year, GSA postponed a final decision on the fate of the program, extending the pilot through fiscal year 2020. This month, we were informed GSA plans to reevaluate the pilot by the end of January 2021. We were also told the pilot will more than likely continue as-is or expand to all GSA Contract SINs.

In our experience, TDR has been a game changer because businesses that participate in the program are not bound by legacy pricing restrictions. As a result, TDR has facilitated the ability of businesses, and small businesses in particular, to participate in the GSA Schedules program. We are encouraged to hear that TDR is likely here to stay and hope GSA extends the option to all contractors in the near future.

Need Help Pursuing TRD Eligible SINs?

FEDSched has been helping companies obtain and manage their GSA Schedule Contracts for more than 30 years. Whether you are pursuing a new GSA Contract or looking to add TDR eligible SINs to your existing contract, we can help. Contact us to discuss.

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Federal Schedules has helped businesses of all sizes successfully obtain, manage and grow with GSA and VA Schedule Contracts for more than 35 years. As the leading government contracts consultant, FEDSched provides an unrivaled level of expertise and guidance businesses can trust to navigate the intricacies of the GSA Schedule Contract and stand out in the federal market space.

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