Transactional Data Reporting – A Look at GSA Mass Mod A509
On January 13, 2017, the GSA Schedule 00CORP solicitation will be updated to incorporate the Transactional Reporting (TDR) pilot program. TDR will affect hundreds of Schedule 00CORP contractors under the Professional Engineering Services SINs: 871-1, 871-2, 871-3, 871-4, 871-5, 871-6 and 871-7. 00CORP Schedule holders who have an impacted SIN should be on the lookout for mass mod A509. It’s important to note the acceptance of the mass mod is voluntary until your contract is up for renewal.
What is Transactional Data Reporting?
The Transaction Data Reporting (TDR) is a pilot program that requires vendors to electronically submit monthly reports on the price or rate the Federal Government paid for every line item or service purchased through GSA acquisition vehicles. This pilot program was first introduced in August 2016 and is being released in phases.
Significant Changes to the New GSA Reporting Requirement that will affect you?
- 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 this excel template (v1.3.6). If your sales and accounting system is not tracking line-item sales with key transaction data identified, you should get started now on updating your accounting system. Your system should begin tracking and providing an output of the following data points in an excel format. This applies to each order that is made against your GSA Schedule and should contain each of the following:
- GSA Contract Number or BPA Number
- Order Number or Procurement Instrument Identifier Number – Incoming sales against your GSA Schedule or BPA should be tracked by an order number field in your accounting system. This field should have one of the following items identified:
- 1. Verbal – If the order came to you by phone or email then you should input “Verbal” in your sales system.
- 2. GSA Advantage! – If the order came in by GSA Advantage! then it should list the order number from the PO (always starts with a Z)
- 3. Task or Delivery Order – If the order came in by task or delivery order then you should list the order number issued. It’s located on block 4 of the SF1449 form.
- Non-Federal entity, if applicable – If a customer places an order against your GSA Schedule as a non-Federal entity such as a reimbursement contract per FAR 51 deviation, state/local government or Non-Government Organization then you’d list the name of the non-Federal entity. Otherwise if the customer is Federal then list ‘Not Applicable’ in this field.
- Description of Deliverable – Provide a brief description of the product or service provided.
- Manufacturer’s Name, products only
- Manufacturer Part Number, products only
- Unit of Measure
- Quantity of Item Sold
- Universal Product Code (UPC), if applicable
- Price Paid per Unit – If your order was firm fixed price and the items/services were not quoted individually then you will report exactly how they were quoted.
- Monthly reporting vs. Quarterly reporting— After you have prepared your accounting system to track the above data. You should note 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 to report quarterly sales and instead will login to https://srp.fas.gsa.gov/ monthly to report detailed information about sales transactions. We cannot stress enough the importance of preparing your sales tracking system in advance in order to adhere to monthly reporting. You will have the option of paying the IFF either monthly or quarterly.
- Digital Certificate – Before you can report your monthly sales you’ll need to ensure the individual reporting the sales has a digital certificate. This is the same certificate used to access GSA eOffer and eMods systems. If you’re a Coley maintenance client we have great news; our portal will be modified mid-2017 to accommodate your monthly sales reporting. You’ll be able to upload your sales to myGSAportal and your Contract Manager will have the ability to report on your behalf. If you’re not on a maintenance plan, no problem! We will offer this service a la carte. Contact us for more information.
- Elimination of Commercial Sales Practices (CSP) disclosure and Price Reductions clause (PRC) – Yes that’s right! After the acceptance of the TDR mass mod your company is no longer required to provide a CSP with modifications nor track the Price Reductions clause granted to your Basis of Award (BOA) customer. This begins the first day of the standard business quarter following acceptance of the mass mod. You are still required to charge the GSA awarded prices/rates or lower.
How to opting out from TDR
If you decide to opt out until your contract’s renewal keep in mind, you’ll still need login the Mass Mod system and choose to ‘Decline’ the mod. Additionally, by opting out then your company will continue to submit the Commercial Sales Practices (CSP) disclosure and follow the Price Reductions clause (PRC) tracking until it becomes a requirement. If you have any questions regarding TDR requirements, please contact us.
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.