GSA Schedule contract compliance is not an easy task--there are so many requirements to abide by and keep up with, and frankly, it can be overwhelming. GSA Schedule contracts can be a great asset to your company, but they require time and dedication. One of the most important parts of maintaining contract compliance is sales reporting. This is the General Services Administration’s (GSA) way of tracking how your company is performing as a contractor, and collecting data on the products and services that are being acquired through the Multiple Award Schedule (MAS) Program.
Two methods that track sales and pricing are Commercial Sales Practices (CSP) and Transactional Data Reporting (TDR). Now that GSA is making TDR mandatory for all MAS contractors soon in Solicitation Refresh #31, it's important you know how these two methods differ and what your future TDR reporting will look like.
Commercial Sales Practices (CSP) are used to determine which of your customers or customer class is offered the lowest price. The CSP-1 document submitted with an offer covers what customer classes you have sold to in the past 12 months and what discounts you have offered these customers. Once you’ve disclosed your discounting practices, you’ll determine your Most Favored Customer (MFC). GSA will then use that to negotiate a “fair and reasonable” discount based on what you’re offering to your MFC.
None of this will be applicable for new offerors who are looking to get a GSA Schedule. Your pricing will still need to be evaluated using market research and it still needs to be considered "fair and reasonable", but the specifics are not required anymore.
If you are reporting Commercial Sales Practices, then you are currently subject to the Price Reduction Clause (PRC). The PRC was created to ensure GSA contractors maintain the discount relationship between their BOA customer and the government.
The PRC is triggered whenever you lower the price for your BOA throughout the entire life of your GSA Schedule contract. Once you lower the price for your BOA, you will have to lower your price for the government, maintaining the same discount delta.
For example, if you lower your BOA prices by 5%, you’ll need to discount 5% to the government as well. This clause will be going away soon when GSA transitions all contractors to TDR.
GSA Schedule contractors CURRENTLY under CSP should be reporting quarterly though the Federal Acquisition Service Sales Reporting Portal (FAS SRP). Quarterly means sales reports are due 30 days after each quarter ends, so reports will be due on January 30, April 30, July 30, and October 30.
For CSP, you report the total sales per Special Item Number (SIN). You don’t need to individually report on each particular contract order. Your Industrial Funding Fee (IFF) which is a fixed percentage of sales under your GSA Schedule, is due on the same day as your quarterly sales.
This frequency will change to monthly with TDR, which we'll go into more detail on below.
Transactional Data Reporting (TDR) is a way for GSA and its partner agencies to collect transactional-level data on solutions purchased through the MAS Program. TDR requires GSA Schedule contractors to electronically report the price the federal government paid for a product or service.
Transactional Data Reporting is not subject to the Price Reduction Clause and no CSP disclosure is required, meaning you do not need to report your MFC/BOA. Unlike Commercial Sales Practices, TDR is reported monthly instead of quarterly. There are also more factors involved in the reporting which we will cover below.
In the past, TDR was only open to contractors who sell under certain SINs, but GSA has slowly expanded the scope to include all contractors in Refresh #31. GSA has delayed this Refresh to March or April 2026, so it hasn't gone into action yet.
As mentioned earlier, under TDR you’ll need to report your sales monthly through the FAS SRP. Your reports are due on the 30th day of the following month. For example, you report your February sales on March 30th, not on the 31st.
Your Industrial Funding Fee is still due quarterly by the 30th day of January, April, July, and October, but you can voluntarily pay it monthly.
Although you do not need to disclose your Commercial Sales Practices or abide by the Price Reductions Clause, this method of reporting is more substantial.
There are 12 items you must keep track of on a monthly basis:
In the past year or so, GSA added 4 more metrics that are currently optional, but may eventually become mandatory as GSA collects more information. They are:
These changes make it possible to monitor pricing compliance, analyze data by location, access cycle times and contract compliance, and analyze data by treasury agency code. The main goal of these changes is to maximize TDR data accuracy.
TDR is on the horizon for everyone, so it's important you understand what could change with your contract maintenance. There are pros and cons to TDR, and GSA has weighed them over the years in the pilot program before rolling it out to all contractors. For example, while the reporting process is more frequent and time consuming, there is less of a compliance risk and you have more freedom with your commercial sales practices.
Below, we have a table of the main differences you have to keep in mind when the full TDR transition is here.
You might be wondering at this point what to do, if you are under CSP. If you are a current contractor, you'll have to accept the Mass Modification and Participate in TDR modification that will come out of Refresh #31. If you are a new offeror, we suggest you prepare your offer under TDR if you're able to. If your offer is not awarded before Refresh #31 comes out (which it most likely won't if you're submitting now unless you're in the FASt Lane Program), then it'll be rejected. Current offerors should look into switching their offer over to TDR. More information can be found in our TDR FAQs blog.
As we've said before, keeping up with your GSA Schedule contract can be difficult and overwhelming. While GSA has resources that can help you make sense of it all, it can still be a very convoluted process especially if you do not have an organized system in place. If you have any questions about your GSA Schedule or need help maintaining your GSA Schedule contract, one of our consultants would be happy to help you.