The release of MAS Refresh 31 marks a significant milestone in this transition, as GSA has expanded Transactional Data Reporting (TDR) to all MAS contracts. With TDR now mandatory across all SINs, GSA has formally moved away from the previous opt-in model. GSA Mass Mod A909 serves as the catalyst for this shift, bringing remaining non-TDR contracts into alignment with the updated program requirements. This update introduces new TDR requirements that directly impact how MAS contractors report sales, maintain compliance, and manage their contracts.

Mass Modification A909 transitions contracts from quarterly reporting under non-TDR to monthly reporting under TDR. For MAS contractors, this change directly affects sales reporting practices, compliance obligations, and overall contract administration. It also represents a broader shift in how GSA evaluates pricing and purchasing data across the MAS program.

To remain compliant, contractors must ensure they have accepted the latest MAS Refresh 31 updates, as well as Mass Mod A909 when applicable. Contractors that need assistance navigating these updates can benefit from working with a team experienced in MAS compliance and contract modifications.

It is important to note that Mass Mod A909 is only issued to contracts that are not currently participating in TDR. Contractors already operating under TDR will not receive this modification. Additionally, if a “Participate in TDR” modification has already been submitted and is in progress, the Contracting Officer will continue processing that action, and the contractor will not receive Mass Mod A909.

TDR is not a new concept. It was introduced as part of a pilot program designed to improve GSA’s visibility into pricing and purchasing trends across federal acquisitions. Additional information is available through GSA’s official Transactional Data Reporting page.

Since its introduction, TDR has expanded in phases. It began as a pilot, where participation was optional and contractors could opt in or out depending on their contract. Over time, GSA expanded the program to additional Special Item Numbers (SINs). In August 2024, TDR was expanded to an additional 67 SINs, followed by another expansion in June/July 2025 that added 62 more SINs. MAS Refresh 27 marked a significant shift during this expansion period, making TDR mandatory for a large portion of SINs and signaling a move toward broader adoption. Under MAS Refresh 31, TDR is now mandatory for all SINs across the MAS program, covering hundreds of offerings across products and services.

As a result, all MAS contractors are required to operate under TDR. For contracts not previously subject to TDR, Mass Mod A909 serves as the mechanism for transition. Contractors are required to review and accept this modification within 90 days of issuance. This requirement applies regardless of contract size or scope and should be treated as a priority action.

Key TDR Changes Under GSA Mass Mod A909

The most significant change is the shift from quarterly to monthly sales reporting. Contractors are now required to submit transactional data on a monthly basis through the FAS Sales Reporting Portal.

Reports must be submitted within 30 calendar days after the end of each reporting month. This creates a more frequent reporting cadence that requires consistent internal tracking and timely data validation.

This change requires more consistent internal tracking and coordination. Treating TDR as a simple reporting update often leads to issues. Without proper preparation, contractors may encounter recurring challenges in collecting and submitting accurate data each month. Establishing clear internal ownership of reporting responsibilities can help reduce these risks. Many contractors find that transitioning from quarterly to monthly reporting introduces new operational challenges, particularly when internal systems are not structured for this level of reporting.

Another key change is the removal of Commercial Sales Practices (CSP), Basis of Award (BOA), and Most Favored Customer (MFC) requirements. While this reduces the administrative burden associated with pricing disclosures, it does not eliminate compliance responsibilities. Instead, the focus shifts to the accuracy and completeness of transactional data. Contractors should ensure their pricing and invoicing systems align with what is reported to GSA.

Mass Mod A909 also incorporates updates to several contract clauses, including those related to reporting, price reductions, and contract modifications. These updated clauses align with TDR requirements and will continue to evolve through future MAS refreshes. Contractors can review the most current solicitation and clause language on SAM.gov. Staying current with these updates is important, as clause changes can affect compliance expectations over time. It is important to understand how these clause updates impact your contract. Reach out if you are looking for GSA Schedule support that will provide ongoing monitoring on your GSA contract.

Once the transition becomes effective, TDR applies to the entire contract. Partial implementation is not permitted. All awarded SINs and associated offerings are subject to the same reporting requirements.

When TDR Requirements Take Effect for MAS Contracts

Acceptance of Mass Mod A909 does not result in an immediate transition.

Contracts remain under non-TDR terms until the first day of the next quarter following award of the modification.

Contractors will continue to report under non-TDR requirements through the end of the current reporting quarter. For most contractors, this means completing quarterly reporting as usual, with TDR reporting beginning at the start of the next quarter. In this case, TDR reporting will begin in July 2026, and the first monthly report will be due 30 days after the end of that reporting month.

This date serves as the official transition point to TDR, after which monthly reporting requirements apply. Understanding this timing is critical for aligning internal reporting processes. Misinterpreting transition timelines is one of the most common issues contractors face during the shift to TDR.

Mass Mod A909 is issued only to contractors whose contracts are currently operating under non-TDR. If your contract is already participating in TDR, you will not receive this mass modification. In cases where a “Participate in TDR” modification is already in progress, the Contracting Officer will continue processing that action instead.

Until the effective date of the transition, contractors must continue to follow non-TDR reporting requirements and guidance. Upon transition, TDR terms and conditions apply to the entire contract for the remainder of the contract period. There is no overlap period where both reporting methods apply.

Misunderstanding the transition timeline is a common issue. Some contractors begin reporting prematurely, while others fail to submit required reports due to confusion regarding the effective date. Clear internal communication can help prevent these issues.

What Happens If You Don’t Accept GSA Mass Mod A909

Mass Mod A909 is a mandatory modification.

GSA requires contractors to accept the modification within 90 days of issuance. Failure to do so places the contract out of alignment with current MAS requirements. This can affect your ability to fully operate under your contract.

Delays in acceptance can result in complications, including delays in processing contract actions, increased oversight from the Contracting Officer, and broader compliance concerns. Maintaining alignment with MAS requirements is essential to preserving contract standing. Contractors should treat this as a compliance requirement, not an administrative task.

What MAS Contractors Should Do to Prepare for TDR

Contractors should begin preparing for TDR as soon as possible.

This includes reviewing and accepting Mass Mod A909, identifying the effective transition date, and evaluating internal systems for monthly reporting readiness. Processes that supported quarterly reporting may not be sufficient under TDR. Adjustments may be needed in accounting, invoicing, and reporting workflows.

Contractors that lack internal resources or experience with MAS reporting requirements may benefit from working with a partner that can help implement compliant processes from the start.

Delaying preparation often leads to incomplete data, reporting errors, and additional administrative burden once reporting begins. Proactive planning can reduce the likelihood of these issues.

TDR represents a broader operational shift in how MAS contracts are managed. Establishing accurate, consistent reporting processes early will reduce risk and support ongoing compliance. Contractors that invest time upfront tend to experience fewer issues over the long term.

If your team needs support navigating TDR requirements, Coley provides compliance, schedule maintenance, and advisory services. We assist contractors with interpreting requirements, implementing reporting processes, and maintaining alignment with MAS contract obligations.

Key Takeaways on GSA Mass Mod A909 and TDR

Transactional Data Reporting is now a standard requirement across all MAS contracts.

Mass Mod A909 formalizes this transition and establishes new expectations for reporting and compliance. It reflects GSA’s continued focus on transparency and data-driven decision-making.

For contractors, the shift is clear. Reporting frequency has increased, pricing disclosures have been reduced, and the accuracy of transactional data is now a central focus. These changes require a more disciplined approach to contract management.

Timely action and preparation will be critical to ensuring a smooth transition and maintaining compliance under the MAS program. Contractors that act early will be better positioned to adapt.

Expert Support for GSA Mass Mod A909 and TDR Compliance

As Transactional Data Reporting becomes mandatory across all MAS contracts, many contractors are finding that maintaining compliance requires more than just understanding the requirements. It requires consistent execution, accurate reporting, and ongoing contract management. Whether you are preparing for your transition to TDR or working to strengthen your internal processes, having experienced support can help reduce risk and improve long term contract performance.

With over 25 years of experience, Coley GCS has helped thousands of companies successfully obtain and manage their GSA Schedule contracts. Our dedicated team provides ongoing support to ensure your Schedule remains compliant, competitive, and positioned for success in the federal marketplace. From initial acquisition to contract modifications and ongoing maintenance, we help simplify the process so you can focus on growing your government business.

If you need assistance navigating Mass Mod A909, preparing for TDR reporting, or managing your GSA Schedule, you can contact our team at hello@coleygcs.com, call us at 210-402-6766, or book time with our team to talk with a GSA expert. If you’re a government contractor looking for business development resources and exploring ways to grow in the federal market, check out FedMap.us — the #1 growth-focused online community for government contractors.