On June 23, 2016, the General Services Administration (GSA) regulations to implement Transactional Data Reporting (TDR). The TDR Rule requires vendors to electronically report details, including the price, of all transactions processed through a GSA Acquisition vehicle.
Companies that currently hold or are in the process of obtaining one of the GSA Schedules listed below will be affected by TDR by the dates listed. While GSA eventually plans to apply the TDR program to all GSA Schedules, they are beginning with Schedules 72 and 58 I. A Solicitation refresh and Mass Modification will be issued for Schedules 72 and 58 I in about a week. Therefore, be on the lookout for mass modification A509. Keep in mind the acceptance of the mass mod is voluntary until a contract comes up for renewal when the acceptance of the modification becomes mandatory.
- GSA Furnishings & Floor Coverings Schedule 72 (8/26/16)
- GSA Professional Audio/Video Schedule 58 I (8/26/16)
- GSA Facilities Maintenance & Management 03FAC (9/9/16)
- GSA Hardware Superstore Schedule 51 V (9/9/16)
- GSA Office Products Schedule 75 (10/17/16)
- GSA Food Service Schedule 73 (11/18/16)
- GSA IT Schedule 70 (11/18/16)
- GSA Professional Services Schedule (PSS) 00CORP (1/13/17)
It is important that mass modifications are reviewed and analyzed by your internal team, knowledgeable individuals and/or experienced advisors to completely understand the business consequences and level of effort required with accepting changes to your GSA schedule contract.
With acceptance of the TDR rule, several important changes will take place. We outline the most significant changes below.
- Monthly reporting vs. Quarterly reporting— Monthly reporting becomes effective on the first day of the business quarter following the acceptance of the mass modification. You will no longer use the 72a portal you’ve been using for years to report quarterly sales and instead will login to https://srp.fas.gsa.gov/ monthly to report detailed information about sales transactions. To report transactional data, authorized users will be required to have a digital certificate, which can be the same certificate used for GSA eOffer and eMods systems.
- Summary Data vs. Line Item Detail—The TDR site changes how vendors report sales. Currently vendors report a summary of aggregate sales per SIN. New TDR requirements will require line-item details to be reported either manually or utilizing a template (v1.3.6). If your sales and accounting system is not tracking line-item sales with key transaction data identification, it must be updated to provide the following outputs:
- Contract Number or BPA Number
- Order Number or Procurement Instrument Identifier Number
- Non-Federal entity, if applicable
- Description of Deliverable
- Manufacturer’s Name
- Manufacturer Part Number
- Unit of Measure
- Quantity of Item Sold
- Universal Product Code (UPC), if applicable
- Price Paid per Unit
- Total Price Sold
- Changing the Basis for “Fair & Reasonable Pricing” —All future modifications and offers under affected SINS will forgo the CSP disclosure in favor of the transactional data systems. TDR will allow Procurement Contracting Officers to use data from TDR and the commercial sector to evaluate price reasonableness. GSA Contracting Officers will now have actual sales data from other vendors to determine if your price is within the competitive range. If it isn’t, the CO will demand that your pricing fall within the competitive range or they will reject your offer/modification request.
- Data Transparency vs. Privacy —GSA intends to make the transactional data available to the public, although some data, including offered pricing, could be designated as “proprietary,” and thus exempt from disclosure.
- Reduced Payment Methods – Paper checks will no longer be accepted. Payments will be made via pay.gov using credit, debit card or electronic check.
ColeyGSA will be monitoring the roll-out and will keep you updated as more information becomes available. We are working on developing an automated reporting tool to simplify the reporting process. If you’re interested in learning more or need assistance with understanding the impacts or implementing TDR, please reach out to us at [email protected]
Vice President for Coley GCS, LLC, a Government Contracts Consulting, Coaching and Training company. Daniel is a Certified Federal Contracts Manager (CFCM) and leads the day-to-day operations of Coley’s consulting practice. He has two decades of experience with the acquisition, management, and marketing of Federal, State, and Local government contracts. Daniel specializes in all aspects of GSA Schedules management and marketing and has helped hundreds of Coley clients remain compliant with the terms of their GSA contract while helping them expand their business.