GSA Expands TDR to 67 New SINs in MAS Solicitation Refresh #22

The news we’ve all been waiting for—since GSA announced they were eventually expanding the Transactional Data Reporting (TDR) pilot to all Special Item Numbers (SINs), prospective and current contractors alike were asking us when they could join the program. Now, we finally have some answers. In Multiple Award Schedule (MAS) Solicitation Refresh #22, which will be released in early August, GSA plans to expand TDR to 67 new SINs. In this blog, we’ll cover the newest TDR news and what other changes GSA plans to implement in MAS Refresh #22.

GSA’s TDR Expansion in MAS Refresh #22

Transactional Data Reporting (TDR) is a GSA Schedule pilot program created to collect transaction-level data on products and services through the MAS program. Since its inception in 2016, TDR has been open to a handful of SINs. Through TDR, you don’t need to report your Commercial Sales Practices (CSP), however, you need to report your GSA sales monthly instead of quarterly, and include data on 11 elements. GSA has recently added 4 new optional fields that may become mandatory.

Right now, TDR is open to 65 SINs. In MAS Refresh #22, GSA plans to add an additional 67 SINs to this list. These additions are all non-configurable products, meaning simple clear-cut products. We’ll list the new ones by Large Category here:

Joining TDR

If one of the SINs you sell under is on the list above, or is on the original list of SINs in the TDR pilot, your entire GSA Schedule contract is eligible for the program. However, the program is optional, and you do not have to opt in even if you qualify. If you decide to participate you must stay within the program.

If you want to opt into TDR, you can submit a “Participate in TDR” modification request. The date will be effective with the start of the next sales reporting quarter (October 1, January 1, April 1, or July 1). From this date, you are required to capture transactional data.

Opting into TDR means you have more pricing flexibility—since you don’t have to report Commercial Sales Practices, you don’t have to abide by the Price Reduction Clause and establish a Most Favored Customer (MFC). There is more of a commitment for reporting though. As mentioned earlier, you’ll report more frequently and comprehensively. If you're not sure whether TDR is right for you, learn more about TDR vs. CSP in our blog.

Overall Changes to MAS Solicitation Refresh #22

Now, let’s talk about the other changes in this refresh. While TDR is certainly the most anticipated and exciting update, there are other important elements to watch out for. Let’s review them:

• A clarification will be added to the requirement for Government Purchase Card (GPC) fees to be built into the MAS awarded price. The note for this clarification will be added to clause 52.232-36, Payment by Third Party, the standard Price Proposal Templates (Read Me First tab) and MAS Modification Guidance on gsa.gov.
• A note has been added to clause I-FSS-600 Contract Price Lists allowing contractors to indicate a software complies with government-specified secure software development practices by adding standard language.
• Minor revisions were implemented to the Modification Products Price Proposal Template (PPT) adding a new price column to the options tab and revising a note for Economic Price Adjustments (EPAs) against Options.
• The MAS Modification guide and sample cover letters will also be revised to add Joint Venture (JV) requirements.
• Lastly, GSA will incorporate clause and provision updates as necessary through the Federal Acquisition Circular (FAC) 2024-05 and GSAR Change 182.

Changes to Large Categories, Subcategories, or SINs

GSA also plans to make changes to specific Large Categories, Subcategories, or SINs in Refresh #22. We’ll cover them below by Large Category.

Facilities

In Large Category B, Facilities, there’s just a minor change. GSA will remove “Four-phase Comprehensive Energy Management Solution” from the SIN instructions for SIN 541690E - Energy Services.

Industrial Products and Services

In Industrial Products and Services (Large Category E), there are a few updates. For SINs 332510C - Hardware Store, Home Improvement Center, Industrial or General Supply Store- Catalog and 332510S - Hardware Store, Home Improvement Center, Industrial or General Supply Store - Store Front, the “point of sale” requirements are removed from the instructions.

Under SIN 332510S - Hardware Store, Home Improvement Center, Industrial or General Supply Store, “sustainable acquisition purchasing requirements of FAR 23” is removed from the SIN instructions.

Lastly, for SIN 325320 - Pest and Animal Control Products and Services, GSA is removing both “Service Contract Act (FAR 22.10) and Davis Bacon Act (FAR 22.404)” applicability, and “U.S. Environmental Protection Agency Comprehensive Procurement Guidelines (recycled content) program or the U.S. Department of Agriculture BioPreferred (biobased) program” from the SIN requirements. The Davis Bacon Act does not apply to this SIN and Service Contract Labor Standards (SCLS) applies to all service offerors already.

Transportation and Logistics Services

Under Large Category K, Transportation and Logistics Services, ‘Page Location’ and ‘Country of Origin’ columns will be added to the following SINs:

• SIN 492110 - Package Delivery and Freight Trucking
• SIN 492210SB Local Courier Delivery Services (SBSA)
• SIN 485 - Ground Transportation
• SIN 532111 - Automotive Equipment Rental and Leasing - Rental Supplemental Vehicle Program (RSVP)

Travel

Finally, under the Travel Large Category (L), ‘Page Location’ and ‘Country of Origin’ columns will be added to SINs 531 - Employee Relocation Solution and SIN 531110 - Long Term Lodging.

Accepting the Mass Mod and Staying on Top of Future GSA Updates

As mentioned before, GSA plans to release MAS Solicitation Refresh #22 in early August. Once it’s released, contractors have 90 days to review and accept the modification(s) in the Mass Mod System. Remember, only authorized negotiators on your GSA Schedule can access this site and acknowledge the changes.

To stay updated on future Solicitation Refreshes, check out our blog and our monthly newsletter. If you have questions about your GSA Schedule or accepting Mass Modifications, one of our consultants would be happy to help you.