The office of Inspector General (IG) at General Services Administration (GSA) released a report in September 2022 after reviewing how contracting personnel perform price analyses to ensure that GSA gets the best prices. They reviewed contracts that use Transactional Data Reporting (TDR) and those that require Commercial Sales Practices (CSP) disclosures and found that negotiations are not guaranteeing that GSA is getting the lowest price from the contractor.

Award Using Commercial Sales Disclosure

Contractors are required to disclose their Commercial Sales Practices (CSP) by class of customer and identify a Most Favored Customer (MFC). Additionally, they submit their commercial invoices to the Contracting Officer as part of the evaluation process. The Contracting Officer then uses these invoices as substantiation of the Contractor’s CSP disclosure. As a result of the CSP disclosure, the Contract is then awarded with the MFC identified as the Basis of Award (BOA) customer, from which GSA’s discount is determined.

After award, Government contractors awarded under the CSP, have the added burden of maintaining the discount relationship between their GSA Schedule pricing and their MFC. If contractors are not prepared to perform the administrative burdens required, they run the risk of falling out of compliance. Contract compliance should not be overlooked since it can lead to expensive fines. Coley GCS Advisors eliminate the administrative burdens and compliance risks our clients by reporting their sales and routinely perform mock audits of those under our GSA contract management support. CSP allows Contracting Officers to negotiate a lower discount to ensure that GSA obtains the lowest price that contractor has to offer.

Benefits of Transactional Data Reporting

Contractors that qualify and participate in the TDR pilot program do not need to disclose their CSP, including the discounts they give to other customers. Rather, they submit a market analysis to demonstrate that their prices are fair and reasonable. The Contracting Officer then negotiates a discount off the Contractor’s current commercial prices. TDR allows customers to report their sales and prices in a more modern way, by comparing the prices to current market rates. If you have been hesitant to pursue a GSA schedule because of the CSP disclosures, now is a great time to look at the TDR requirements.

Inspector General Report Findings

The IG found that there is no conclusive way to confirm that GSA is getting the lowest rate from Contractors using TDR. Although the IG recommends ending the TDR program, the Federal Acquisition Service (FAS) has plans to expand this program to all MAS contracts.

Coley has experience helping companies win a TDR schedule, transition to the TDR program, and stay compliant while using the TDR program. We are available to help make the process easy. Contact us today at or 210-402-6766 to get started on obtaining your GSA Schedule—a critical step on your road to success in the government market.

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