If you currently have a GSA Schedule, you have likely heard the term Transactional Data Reporting (TDR) more recently. If you have not heard of Transactional Data Reporting, it is a GSA Schedule program for reporting sales that was first rolled out in 2016. TDR is a way for GSA and its partner agencies to collect transaction-level data on solutions purchased through the Multiple Award Schedule (MAS) program.
Ultimately, the purpose is to equip the government’s acquisition workforce with the information needed to make data-driven decisions that save taxpayer dollars. TDR also allows contractors to opt out of Commercial Sales Practices (CSP) and reporting, which could be a benefit for your company. Since GSA expanded TDR to several contractors, and plans to roll it out to all contractors eventually, let’s review what TDR is and how to report your TDR sales successfully.
GSA has implemented major changes to the way in which TDR is being administered for all contractors across the GSA Schedule. Previously, TDR was only available for certain Special Item Numbers (SINs), and contractors had the option whether to use the TDR program.
However, GSA contractors with TDR eligible SINS are now REQUIRED to opt in to the TDR program, and GSA recently expanded the number of contractors who are eligible. You can check the full list of eligible SINs on GSA’s website. If you have one eligible SIN, then you now have to switch over to TDR.
GSA plans to make all SINs eligible for the TDR program soon, meaning that ALL contractors will soon be on the TDR program. There are multiple reasons for this change.
Since TDR reporting is more expansive, it allows GSA to use the data about the prices paid for products and services sold through the Multiple Award Schedule and helps them better understand what the government purchases. TDR also is a less burdensome alternative to legacy pricing disclosure requirements for vendors, which makes compliance and schedule management easier for contractors.
If you are a GSA contractor and do not yet have a TDR eligible SIN, be on the lookout for updates from GSA in the near future regarding the topic, because the transition will soon be a requirement.
To understand how TDR reporting works, it’s important you know the differences between TDR and Commercial Sales Practices (CSP) first.
One of the major distinctions for contractors who are new to the TDR program is that once contractors opt in to TDR, they are no longer required to disclose their Commercial Sales Practices. Commercial Sales Practices are used to determine which of your customers or customer class is offered the lowest price. So, contractors under CSP are required to report their Most Favored Customer (MFC) along with other discounting and sales practices such as following the Price Reductions Clause. Once you move to the TDR program as a contractor, you do not have to go through all those commercial sales disclosure hoops.
Similar to many options that are presented through the GSA Schedule, Transactional Data Reporting will come with pros and cons. The pros include more liberty with discounting, it’s not subject to compliance with the Price Reductions, and there are no CSP disclosures or maintenance required.
The cons of TDR are mostly relegated to sales reporting. These include more substantial reporting with 12 additional items and having to report sales more frequently (monthly instead of quarterly). We’ll talk about this in more detail below.
Once contractors opt in to TDR, they are required to report GSA sales of their products and services monthly. Additionally, there are 12 items you will need to keep track of on a monthly basis:
The four optional (and maybe eventually required) elements are:
Both CSP and TDR methods are uploaded through the Federal Acquisition Service Sales Reporting Portal (FAS SRP). Most of the options within the FAS SRP are very straightforward, but more specific instructions can be found in our blog about sales reporting.
For TDR contractors, sales reports are due monthly, but the corresponding Industrial Funding Fee (IFF) can be paid either monthly or quarterly. The IFF is 0.75% of GSA contract sales and is used to cover GSA’s cost of operating the Federal Supply Schedules (FSS) program. TDR contractors can select to make the IFF payment with the following methods:
Keeping track of GSA sales separately from your commercial/non-GSA sales is one of the best ways to be prepared to submit sales at the end of each month. This will help maintain a general idea of how well GSA sales are tracking. Sometimes, GSA contractors have trouble figuring out what a GSA sale is, so we suggest you not only keep your sales separate, but know how to differentiate between them. No one wants to overpay their IFF to GSA.
It’s also important to be aware of the 12 items that are required for TDR reporting, so you know what information to pull when it’s time to report and if anything has changed in the last month, you are prepared to make any necessary changes.
Overall, Transactional Data Reporting presents GSA Schedule contractors with a great opportunity to offer competitive pricing to federal buyers. Although the sales reporting can be more cumbersome, organizing GSA sales and being aware of the information that is needed can help offset the extra work required for TDR sales reporting.
If you are recently eligible for TDR, or want to learn more about TDR and how to manage your GSA Schedule, one of our consultants would be happy to answer any of your questions.