Learn about the GSA's shift to optional Transactional Data Reporting (TDR) for Schedule Contractors and its potential impact on contract compliance and business strategy.
As of November 30, 2017, the General Services Administration (GSA) will be implementing a significant change to the Transactional Data Reporting (TDR) pilot program. Previously, participation in this program was mandated for all companies holding a GSA Schedule Contract and were part of the TDR pilot. Now, participation has become optional, marking a crucial shift in the program's implementation that was initially launched in August 2016. Here are the key points regarding this noteworthy update:
Initiation: Launched in August 2016 for select GSA Schedules.
Purpose: Prior to the update, contractors were required to report transaction-level data on GSA Schedule sales.
Exemption from PRC: Participating contractors enjoyed an exemption from the Price Reductions Clause (PRC). Moreover, there was no need to establish a Basis of Award customer.
Mandatory Participation: At the outset, new contracts or 5-year extensions under selected Schedules were required to participate.
Optional Participation: As of November 2017, TDR became optional for certain contractors.
Voluntary Participation: Those who voluntarily opted into TDR cannot reverse their decision.
Opt-Out Opportunity: Contractors mandated into TDR were given a one-time choice to opt-out, thereby having the opportunity to revert to traditional pricing structures.
Notification: Eligible contractors were notified via email and given 60 days to respond.
Resubmission of Pricing: Contractors choosing to opt-out must revert to traditional GSA Schedule pricing structures. This involves resubmitting Commercial Sales Practices and negotiating Most Favored Customer (MFC) or Basis of Award (BOA) terms.
Compliance with PRC: These contractors must accordingly adhere to the Price Reductions Clause. This requires ongoing tracking of pricing and discount relationships.
Contractors must evaluate the potential benefits of detailed reporting under TDR. They need to consider it against the obligations of traditional GSA pricing structures, including complying with PRC.
Your choice to opt-in or out should take into account administrative burden, transparency in pricing, and strategic alignment with business goals.
Contractors who are uncertain about the impact of TDR can seek professional advice. If you are considering opting out of your GSA Schedule Contract, it may be beneficial to consult with experts in the field.
The GSA also provides valuable resources and support for making informed decisions regarding TDR participation.
Looking ahead, GSA may continue to evaluate the effectiveness and participation in the TDR program. This could potentially lead to future changes or expansions.
Contractors holding a GSA Schedule Contract should stay informed about developments in the TDR program. It is crucial to understand how these changes could impact their contract compliance and business strategy. Led by former GSA Schedule Reviewer, we offer the best GSA Schedule Consulting services.
Pedro has extensive background as a Contracting Officer and Contract Specialist, has worked across seven federal agencies, managing contracts totaling over $1 billion in the professional and tech sectors. His notable tenure includes serving with the DoD/DARPA during the inception of their robotics program. Additionally, he played a pivotal role in initiating the Cyber Special Item Number (SIN) within the GSA's IT Schedule 70 as a Team Lead. After graduating from Harvard, he started Blackfyre to help you win your next contract.
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