UPDATE: As of November 30, 2017, participation in TDR is no longer mandatory for companies that hold a GSA Schedule in the TDR pilot program.
GSA’s Transactional Data Reporting (TDR) pilot was rolled out to select GSA Schedules beginning in August of 2016. Love it or hate it, TDR offers advantages and disadvantages to GSA Schedule Contractors. TDR requires contractors to submit monthly reports on the price paid for GSA Schedule Contract products. While reporting requirements are more extensive, contractors participating in TDR are not subject to the Price Reductions Clause (PRC) and do not need to establish or track a Basis of Award customer/customer class.
Since its start, companies were required to participate in TDR if they pursued a new GSA Contract or exercised a 5-year extension option for a GSA Schedule included in the TDR pilot. However, as early as April 2017, GSA began to discuss making TDR optional for all contractors.
Citing better than anticipated voluntary participation in TDR, GSA officially announced its intent to make the program optional in a recent Interact posting and blog article. GSA expects to issue a Solicitation refresh in November that removes language referencing mandatory participation in TDR.
Opting-Out of TDR
Companies that volunteered to participate in TDR will not have the option to reverse their decision. However, contractors that were required to participate in TDR will have a one-time opportunity to opt out of the program. Eligible contractors will receive an email from GSA regarding TDR opt-out and will have 60 days to respond. Companies that wish to leave the TDR pilot will have to revert back to the traditional GSA Schedule pricing structure.
The original GSA pricing structure involves submitting Commercial Sales Practices, current pricelists, and negotiating Most Favored Customer (MFC) or Basis of Award (BOA). It also requires compliance with the Price Reductions Clause (PRC), which requires contractors to track pricing and maintain the MFC/BOA discount relationship. According to a Fact Sheet released by GSA, companies that had previously submitted pricing information and negotiated MFC/BOA will still be required to resubmit and negotiate these items.
For more information or to discuss how TDR impacts your GSA Schedule Contract contact us or call 703-709-8700.
