In April 2026, GSA released Multiple Award Schedule (MAS) Solicitation Refresh #31, making the pilot Transactional Data Reporting (TDR) program mandatory for all new offerors and existing contractors. This update significantly changes how GSA MAS offerors prepare their price proposal, as the TDR program removes the requirement for offerors to submit pricing support to justify their commercial rates for their service and/or product offerings.
While offerors now have more flexibility in the types of products or services they can propose, GSA’s reviewing Contracting Officer (CO) will still evaluate whether the proposed prices are fair and reasonable. Thus, GSA Schedule pricing support remains a crucial element for both GSA MAS offers and modifications in the submission and review processes. Throughout this blog, we’ll discuss the relationship between TDR and GSA Schedule pricing support, several acceptable types of pricing support, and how to navigate pricing data when typical examples of pricing support may not be available.
An Overview of the Transactional Data Reporting (TDR) Program
First, let’s quickly recap the TDR program for GSA MAS. TDR was introduced to the MAS Program in 2016 to capture more in-depth data on the products and services being purchased by agencies. Under TDR, contractors are required to report monthly on multiple data elements associated with their GSA MAS sales, providing GSA with insight into the items bought and the actual prices paid.
Originally, TDR-eligibility was limited to select Special Item Numbers (SINs); however, across several Multiple Award Schedule Solicitation Refreshes, TDR slowly expanded to all product-based SINs and select service-based SINs. In Refresh #31, contractors’ and new offerors’ participation in TDR became mandatory, regardless of SIN.
Before TDR became mandatory, the sales reporting method for non-TDR contractors was Commercial Sales Practices (CSP), which required contractors to report their total sales received per SIN on a quarterly basis and disclose their specific customer(s) that received discounts and concessions in the previous 12 months commercially to inform additional discounts for their GSA Schedule prices. Pricing support was also required for each proposed labor category or product for offerors submitting a GSA MAS proposal under a non-TDR SIN.
Is Pricing Support Required Under TDR?
No, pricing support is not required to include with your GSA MAS offer submission under TDR, per Multiple Award Schedule Solicitation guidance. However, we recommend including GSA Schedule pricing support to assist in the CO’s evaluation of your price proposal.
How is GSA Schedule Pricing Evaluated?
Consistent with Federal Acquisition Regulation (FAR) 15.403-1 (GSA Class Deviation RFO-2025-15) and GSAM 538.270-2, your assigned CO will utilize existing sources of government data (e.g., data received through TDR sales reports) and other available data to evaluate the fairness and reasonableness of your proposed rates.
However, if existing data or market research is not sufficient to complete their price analysis, the CO is allowed to request additional documentation from offerors to assist in their determination of price reasonableness. COs may specify the pricing support they would like to receive, such as previous sales.
Thus, while not required, it’s a good idea to include pricing support with your initial GSA MAS offer submission to avoid potential clarifications regarding the validity of the proposed rates or requests for pricing support later. We’ll break down compliant forms of GSA Schedule pricing support to include with your proposal next.
What Can Pricing Support Look Like for a GSA MAS Offer?
The current Multiple Award Schedule Solicitation doesn’t specify the types of pricing support that can be included in a GSA MAS offer; however, instructions prior to Refresh #31 stated that compliant formats for GSA Schedule pricing support included:
- Copies of published or publicly available commercial catalogs/price lists
- Invoices
- Contracts
- Quote sheets
This documentation will directly support the commercial rates for your proposed products or services. GSA expects you to offer a discount on your commercial rates, so your proposed GSA MAS ceiling rates will be lower than the prices stated in the supporting documentation.
All pricing support should be from recent projects to prove the commerciality of the rates. Pricing support can vary between service or product offerors, so let’s review these options below.
Pricing Support for Services
If your offer includes hourly labor categories, an invoice billed to a customer using a Time & Materials (T&M) structure is a great document to use as GSA Schedule pricing support. COs prefer copies of invoices that clearly state the price per hour and title for a labor category. The same concept applies for other types of services, such as fixed price solutions/services or training courses, depending on the unit of measure (e.g., each, per foot, per day, etc.).
However, not all companies invoice using T&M practices. You may bill “lump sums” to your customers each month for work performed. In this case, you could use this fixed-price invoice in conjunction with a supporting timecard or similar project documentation to connect the total fee billed to the customer with the hours worked per employee to result in the proposed commercial hourly rate. A contract-awarded rate card that outlines the labor category titles and associated hourly rates is also acceptable pricing support.
Pricing Support for Products
Historically, invoices are also the preferred type of pricing support for products. The invoice should include the product’s name and unit price. Published pricing support, such as a product catalog or an item’s page on your website, can also be used to justify the commercial rates for each product.
Pricing for Commercially Available Off-the-Shelf (COTS) items will be evaluated for fairness and reasonableness by GSA using a market threshold algorithm. The model used to calculate the market threshold has recently been updated as part of GSA’s Pricing 2.0 effort. This calculation utilizes several pricing data sources to establish a maximum acceptable price per COTS item, including government order prices from MAS TDR reports, commercial catalog prices, and government contract prices from GSA Advantage!, FedMall, and NASA SEWP.
For new offerors, the algorithm will be applied during a CO’s review of the price proposal to evaluate which COTS items’ prices fall above their market thresholds and will be generated using the Compliance & Pricing (C&P) Report. For existing contractors submitting a modification, the C&P report will be generated in the FAS Catalog Platform (FCP). Based on the report’s results, you will have the following options:
- Lower the item’s price to the market threshold price
- Remove the item
- Provide supporting pricing justification for a higher item price
This market threshold algorithm is applicable for new offerors and existing contractors reselling COTS products and not those who manufacturer their own items.
What If You Don’t Have Pricing Support?
Your company may not have the best invoices or any published catalogs to submit with your offer or contract modification as pricing support. GSA has several resources for existing contractors or new offerors to conduct market research to include with their modification package or proposal as an alternative or complement to GSA Schedule pricing support.
For services, the Contract-Awarded Labor Category (CALC) Tool provides insight regarding contractors’ awarded ceiling rates for distinct labor categories. You can filter labor category search criteria by SIN, education, experience, business size, worksite, and more, as well as view data by median and percentiles or average and standard deviation. Using GSA eLibrary, you can search competitors by name or SIN and download their price lists to compare your prices.
Product offerors can search part numbers via GSA Advantage! to compare prices and delivery terms across various resellers. Demand data derived from monthly TDR reports is available to review annual demand quantities and average transaction prices for popular items sold through the Multiple Award Schedule.
You should also conduct market research prior to the submission of your proposal to understand how your proposed GSA MAS prices align with current contractors’ prices for similar offerings. GSA’s reviewing CO will likely engage in similar market research during their price analysis; thus, you can be prepared for any additional discounts they may request during the negotiations stage of the offer review process.
Navigating GSA Schedule Pricing Support Under TDR
While it’s optional to include pricing support for a new GSA MAS offer under TDR, GSA’s reviewing CO has the authority to request this data during the offer review process. You may have to remove several offerings from your proposal if you are unable to provide the requested documentation. So, it’s a good idea to include pricing support with your GSA MAS proposal or have readily available documentation on hand to support your proposed prices.
The pricing section of a GSA MAS offer can be complex, especially depending on the SIN(s) being pursued; if you would like assistance in developing a compliant price proposal and incorporating pricing support into your offer, reach out to our team, and we would be happy to help.
