On November 18th The General Services Administration (GSA) announced that the Schedule 70 solicitation has been updated to incorporate the Transactional Data Reporting pilot (TDR). This pilot program will affect thousands of Schedule 70 contractors under the following SINs: 132-8, 132-32, 132-33, 132-34, 132-54, and 132-55. For current Schedule 70 holders who have one of the impacted SINs it is important to note that contractors participation in this mass mod is optional. If you choose to decline the mod, you will opt out of the TDR pilot and continue with the Most Favored Customer (MFC) and Price Reduction Clause (PRC) System until it becomes a more formal requirement.
What is Transactional Data Reporting and Why is it Being Implemented?
The Transactional Data Reporting (TDR) pilot aims to aggregate purchasing data for products and services delivered during the performance of the contract through a user friendly, online reporting system. The report would include transactional data elements such as unit measure, quantity of item sold, universal product code, if applicable, prices paid per unit, and total price. The pilot hopes to increase visibility into, both, prices paid by other government customers and, attention on “horizontal pricing” under the Federal Supply Schedule (FSS). “Horizontal pricing” would allow government customers to compare your pricing to other vendors pricing, and would effectively lead to the demise of Most Favored Customer (MFC) pricing, or “vertical pricing” where government customers would compare proposed GSA prices to commercial sector customers.
GSA plans to evaluate prices paid under the pilot to commercial benchmarks and other available data on commercial pricing, as well as prices previously paid prior to the pilot where data is available. GSA plans to judge the TDR pilot by, (1) performing analyses and measure the results and impact of the pilot, and (2) taking vendor feedback comparing experience with the pilot to that of the tracking requirements of the Price Reductions Clause System (PRC). If the results of the pilot confirm that using transactional data is an effective pricing model, its use would be broadened.
GSA believes that the transactional data reporting clause could reduce the annual burden on contractors by more than 85 percent, or approximately $51 million in administrative costs to contractors, when compared to the burden hours associated with monitoring pricing under the price reductions clause in its current configuration. GSA further believes that use of the transactional data reporting clause as an alternative to PRC addresses recommendations made by independent reviewers of the FSS program over the past several years.
How Is This Going to Affect You as a Schedule 70 Contractor?
The good news again, is that if you already have a Schedule 70 contract with the government, participation in this pilot is optional. However, all new contracts under the affected Schedule 70 SINs will be required to participate in TDR. It also appears likely that contractors renewing applicable FSS contracts during the pilot program will be required to transition to the TDR pilot.
GSA plans to update its systems in order to collect and analyze transactional data. Data submission will be enabled through multiple electronic interfaces with the goal being to make the reporting process as streamlined, secure, and efficient as possible for contractors. Contractors will only have to submit the transactional data GSA cannot access via other means such as SAM, FPDS, or the GSA contract management systems. GSA provides instructions and offer training to vendors on how to report transactional data for FSS orders here: https://tdr.gsa.gov/portal/training/
Should you have any additional questions on TDR, feel free to reach out to us for assistance.