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Should I stay or should I go? Transactional Data Reporting (TDR)

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Centre Law & Consulting

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Over a year ago, GSA published a final General Services Acquisition Regulation (GSAR) rule incorporating Transactional Data Reporting (TDR) into select product and service schedules in the Multiple Award Schedules (MAS) program. Initial participation in the TDR pilot was optional for existing contractors. However, new offerors and existing contractors with upcoming options were required to participate in the pilot.

GSA is now making participation in the TDR pilot voluntary. Any vendor required to accept TDR with a new pilot offer, had a TDR option exercised, or added a TDR SIN to their contract will have an opportunity to opt out of TDR.  If a vendor does not take advantage of this one-time opt out, there will be no additional opportunities to get out. You can also opt into TDR on pilot schedules but remember there will be no additional chances to withdraw once you make this election.

As a caveat, any vendor who voluntarily accepted the TDR Implementation Mass Mod (A509) will be required to stay in TDR.

GSA anticipates refreshing TDR schedules in mid-October. Schedules 03FAC, 51V, 58 I, 72, 73 and 75 will be refreshed to add the legacy clauses back to the solicitation and TDR SINs on Schedules 70 and the Professional Services Schedule (PSS) will reflect the removal of language pertaining to mandatory participation.

Once the solicitations are refreshed and not before, vendors will receive a notification from their Contracting Officer (CO). A vendor will have 60 days to respond to their CO with their intent. If no response is received within the 60 days, a vendor will remain in the TDR pilot.

What will be required if you make the decision to opt out of TDR?

  • Provide updated Commercial Sales Practices (CSP), current pricelist, and any other information requested by the CO
  • Re-establish a Most Favored Customer (MFC) and Basis of Award (BOA) customer
  • Identify a price/discount relationship as required by the Price Reduction Clause
  • Ensure that your pricing is still fair and reasonable
  • Update your contract via a formal modification to incorporate any revised terms and conditions

What are the effective dates for vendors who opt out of TDR and when will Price Reduction tracking become effective?

  • The actual modification opting out of TDR will become effective on day 1 of the next business quarter (January 1st, April 1st, July 1st and October 1st)
  • Price Reduction tracking will begin on day 1 of the business quarter following the date of the modification to opt out
  • The first 72A reporting period will begin on the 1st day of the business quarter following the date of the opt out modification. Continue to remit Industrial Funding Fee (IFF) in the FAS Sales Reporting System (TDR) until that time.

If you have any questions on whether you should stay or opt out of the TDR pilot, please contact a member of the GSA consulting team.

About the Author:

Maureen Jamieson | Centre Law & Consulting Maureen Jamieson 
Executive Director of Consulting

Maureen Jamieson has more than twenty-five years of experience managing federal contracts. Maureen is highly experienced in solving client pricing problems and implementing effective pricing strategies for placing products and services on GSA Schedule contracts. Maureen also frequently works with clients on effective selling and marketing strategies in the federal market space and is highly skilled as a federal contracts capture or proposal manager.

The post Should I stay or should I go? Transactional Data Reporting (TDR) appeared first on Centre Law & Consulting.


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