GSA wrapped up the 2021 calendar year with a big announcement regarding Transactional Data Reporting (TDR). At the time, GSA planned to extend TDR to all GSA Multiple Award Schedule (MAS) Special Item Numbers (SINs) in fiscal year 2022. While GSA has shifted the timeline, they are still committed to moving TDR out of the pilot phase and opening it up to all interested GSA MAS contractors.
Read on to learn more about Transactional Data Reporting
- What is TDR?
- Benefits of Transactional Data Reporting
- TDR Reporting Requirements
- TDR & Category Management
- Latest Updates on the Expansion
Transactional Data Reporting Highlights
What is TDR? Why is the Expansion of Transactional Data Reporting Important?
GSA created Transactional Data Reporting to support government-wide Category Management initiatives. The program modernizes how contractors negotiate and maintain pricing under the GSA MAS program. In exchange for monthly sales reports, TDR allows companies to enjoy the benefits of the GSA MAS Contract, without the burden of the legacy Price Reductions Clause (PRC) and the disclosures and restrictions that come with it.
Since its introduction in 2016, TDR has only been an available option to companies that hold or pursue select SINs. Companies that participate in the program widely view it as successful. In 2020, GSA indicated they were continuing to evaluate TDR and that the program would most likely continue as-is, under select SINs, or expand to include all GSA SINs. However, despite favorable reports from GSA, the fate of the program became uncertain after a negative Office of Inspector General (OIG) report become public earlier this year. Irrespective of the view of the OIG, GSA’s confirmation this month that TDR will be available to all GSA MAS Contractors is welcome news to the contracting community.
Benefits of Transactional Data Reporting
A GSA MAS Contract provides contractors with a broad range of benefits. However, it has traditionally come with a tradeoff – disclosing commercial sales practices, tracking sales to a Basis of Award Class of Customer, and continuous adherence to the infamous PRC.
To obtain a GSA MAS Contract without TDR, companies must disclose their commercial sales policies and practices. They must also offer pricing that reflects equal to or better than the most favorable pricing granted to a customer or class of customers that most resembles the buying habits of the federal government. This is known as the Most Favored Customer (MFC) or Basis of Award (BOA). Following the award of a GSA Contract, companies must track pricing to their MFC/BOA, report any price reductions, and depending on the circumstances, reduce their GSA pricing. TDR eliminates all of these burdensome responsibilities for companies.
TDR Contracts 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
TDR Reporting Requirements
Companies that participate in TDR must report transactional level data. This includes the price paid by federal buyers for products and services purchased through the company’s GSA Contract. The transactional level data provides the government with market intelligence to make smarter acquisitions and achieve taxpayer savings, which are key Category Management goals.
TDR and Category Management
GSA Schedule Contractors view Transactional Data Reporting as something that allows them to avoid the Price Reductions Clause (PRC) and tracking pricing relationships. However, as we mentioned earlier, GSA introduced TDR to the GSA Schedules program as a way to support Category Management.
Category Management is an initiative that drives federal contract awards through specific contract vehicles and away from open market procurements and duplicative contracts. Agencies are tasked with increasing their “Spend Under Management” each year, which means spending through contract vehicles classified as Tier 1, 2, or 3 solutions.
As a whole, the GSA MAS Contract is a Tier 2 solution, but certain SINs are Tier 3, Best-in-Class solution. Transactional data is a crucial component of evaluating the effectiveness of government-wide Category Management. Transactional data is also an eligibility requirement for Best-in-Class (BIC) solutions. Opening up all GSA MAS Contract SINs to Transactional Data Reporting, provides the possibility of additional SINs receiving a future BIC classification.
Latest Updates on the Expansion
GSA’s Steve Sizemore, provided an in-depth review of Transactional Data Reporting during a webinar last week. Steve also provided a much anticipated update on the program’s expansion.
When Will TDR Expand to all GSA MAS SINS?
While there is no firm date for the expansion, GSA hopes to expand Transactional Data Reporting in the next few months. GSA is diligently working on the internal framework to ensure a smooth transition to full access to TDR. This includes finalizing system and data enhancements, and training GSA’s acquisition workforce. GSA wants to ensure its workforce fully understands the differences in requirements between a TDR contract and a non-TDR contract.
How Will GSA Expand TDR?
GSA will issue a solicitation refresh to open all Multiple Award Schedule SINs to Transactional Data Reporting. GSA MAS Contractors will receive a mass modification and have the option to participate in TDR through a modification. It is important to note, once you opt-in to TDR, you may not reverse that decision. However, if you previously opted out of the program, you’ll have the opportunity to opt-in when the mass modification is issued.
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