GSA Schedules offer the opportunity for contractors to provide their products and services to federal agencies at pre-negotiated rates, making it easier for the government to acquire what it needs and for commercial companies to secure reliable contracts. However, securing a GSA Schedule is not simply a matter of filling out paperwork and submitting it to GSA. Rather, vendors must ensure they are offering fair and reasonable pricing to the government. Once this pricing is determined in the award process, contractors must maintain their established rates and report their GSA sales quarterly or monthly.
There are two ways GSA contractors can choose to report their sales—following Commercial Sales Practices (CSP) or Transactional Data Reporting (TDR). TDR is only available to certain contractors, but GSA plans to open it up to everyone in the near future. So, let’s discuss the ins and outs of both options and evaluate which one may be best for your company.
Understanding Commercial Sales Practices
At the heart of Commercial Sales Practices is price transparency. Vendors seeking a GSA Schedule must provide information about their pricing practices that allow the government to evaluate the fairness of their rates. If you are opting into Commercial Sales Practices, this includes disclosing the prices paid by commercial customers for the same or similar products or services, and determining a Most Favored Customer (MFC) and Basis of Award (BOA) customer. Most of the time this customer is the same. By sharing this information, vendors help to ensure that the government is receiving prices that are competitive with what is being offered in the commercial market.
The disclosure of commercial pricing can take several forms. Vendors may provide an electronic catalog that includes pricing information for their products and services, or they may submit sales data reports that detail their sales over a specified period of time. In either case, the information must be presented in a way that is easily understandable and allows the government to evaluate the fairness of the prices being offered.
Following the Price Reduction Clause
One key aspect of Commercial Sales Practices is the requirement to offer discounts to the government. Vendors seeking a GSA Schedule must provide the government with their best pricing, which includes any discounts that they offer to their commercial customers. To determine the appropriate level of discounts to offer, vendors may use a pricing model that takes into account factors such as volume discounts, prompt payment discounts, and other incentives. Once this discount percentage is determined, contractors are subject to the Price Reduction Clause, meaning if you lower your prices for your Basis of Award customer, you will need to lower it accordingly on your GSA Schedule.
Reporting Under Commercial Sales Practices
Another important aspect of Commercial Sales Practices is the requirement to maintain accurate and complete records. Vendors seeking a GSA Schedule must keep detailed records of their sales and pricing practices, including information on the discounts and incentives offered to their customers. These records must be kept up-to-date and must be available for inspection by the government at any time.
Contractors under CSP must report their GSA sales quarterly. 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. What do you report on? 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.
Understanding Transactional Data Reporting (TDR)
Transactional Data Reporting (TDR) program is a data collection and reporting system that GSA has been piloting for certain SINs. If contractors opt into TDR, they are exempt from the Price Reductions Clause and CSP reporting requirements. This means, contractors are NOT required to provide Commercial Sales Practices disclosures identifying discounts, terms, and conditions offered to your commercial customers.
Under TDR, GSA Schedule contractors are required to report transactional data, including prices paid and quantities sold, to the government on a monthly basis.
Why Did GSA Introduce TDR?
TDR was introduced as part of the GSA's effort to simplify the reporting process for contractors and improve the accuracy of pricing information. By collecting transactional data, the GSA can better analyze pricing trends and ensure that government customers are receiving fair and reasonable prices.
One of the key benefits of TDR for contractors is that it eliminates the need for separate PRC and CSP reporting. This can save contractors time and resources by streamlining the reporting process. Additionally, TDR can provide contractors with valuable insights into their pricing strategies and help them identify areas where they can improve.
Another advantage of TDR is that it allows the GSA to be more responsive to changes in the market. By collecting transactional data on a regular basis, the GSA can quickly identify trends in pricing and adjust its contracts accordingly. This can help ensure that government customers are always receiving the best value for their money.
Reporting Sales Under TDR
While TDR may seem like the better choice over CSP because it eliminates the Pride Reduction Clause and other commercial sales requirements, it involves more frequent and involved reporting. Contractors under TDR must report their sales monthly by the 30th day, and must include 11 different elements for each data transaction. These are:
- Contractor or Blanket Purchase Agreement (BPA) Number
- Delivery/Task Order Number/Procurement Instrument Identifier (PIID)
- Non Federal Entity, if applicable
- Description of Deliverable
- Manufacturer Name
- Manufacturer Part Number
- Unit Measure (each, hour, case, lot)
- Quantity of Items Sold
- Universal Product Code
- Price Paid Per Unit
- Total Price
The IFF is still due quarterly, but contractors can also pay it monthly.
As you can see, while TDR eliminates a big compliance headache for contractors, it is a little more involved, so contractors should evaluate which sales reporting option works best for them. For now, your company may not be eligible for TDR until GSA opens it up to all contractors, but it’s still something to consider. A list of TDR eligible SINs can be found on GSA’s site.
Do You Need Help with GSA Schedule Sales Reporting?
Preparing your Commercial Sales Practices or Transactional Data Reporting is an important part of maintaining your GSA contract. Sales reporting can become tedious or can be difficult to manage especially if you are a small business or are new to the world of GSA contracting. If you have questions about sales reporting, whether it’s CSP or TDR, check out these blogs:
- How Do I Report My GSA Schedule Sales?
- How Do I Report My Sales with TDR?
- Best Practices for GSA Invoicing and IFF Reporting
Of course, we are also here to help. If you aren’t sure which path to choose or you need help managing your Schedule, one of our consultants would be happy to assist you.
