.png "Patrick Morgans")
As most contractors know, or will find out, maintaining compliance is one of the most important factors in doing business with the government. One of the most important, and frustrating, aspects of compliance for GSA Schedule holders is the tracking of Commercial Sales Practices (CSP). The idea of disclosing your Commercial Sales Practices, and tracking to make sure that their relationship to GSA pricing are not disturbed, can be daunting to many GSA Schedule holders and prospective contractors.
If this describes you, you may want to look into whether or not you are eligible to opt into Transactional Data Reporting (TDR). Under this option, you report additional “transactional data,” twelve mandatory fields, when reporting your GSA sales. You also report sales on a monthly rather than quarterly basis. However, you are free from the requirement to disclose your CSP and the compliance risks that entails. TDR is a great option for many contractors, and if it has piqued your interest, I would like to guide you through the process to opt into TDR.
Transactional Data Reporting (TDR) Eligibility
While TDR can be a great option for many contractors, not all contractors are eligible for the TDR program. In order to be eligible for TDR, GSA Schedule holders must have at least one Special Item Number (SIN) that is eligible for the TDR program. The easiest way to assess whether or not a SIN you have on your Schedule or are considering is TDR applicable is to check on GSA’s “Consider transactional data reporting” webpage. This webpage is also a great resource if you want to find out more about the basics of TDR, including how TDR requirements stack up against non-TDR requirements.
Alternatively, you can always check the MAS Available Offerings attachment to the Solicitation. This attachment takes the form of a spreadsheet with a list of SINs and includes a column noting whether or not each SIN is TDR applicable.
If any of the SINs on your Schedule are eligible for the TDR pilot, you are able to opt your entire Schedule into TDR. A common misconception is that TDR only applies to SINs that are TDR eligible. The reality is that if you opt into TDR, it applies to the entire Schedule, so you would be reporting transactional data monthly and exempt from disclosing Commercial Sales Practices for the entire Schedule.
If you would like to opt into TDR and do not currently have a TDR applicable SIN on your Schedule, I would recommend looking into the list of TDR applicable SINs and discovering if any of the listed SINs is applicable to the services your company offers. There are a variety of SINs from many different large categories that are TDR applicable, and GSA actually just expanded the list of TDR applicable SINs as part of Solicitation Refresh 22. If you checked in the past and have been disappointed that none of the TDR applicable SINs seem relevant to your company, it’s worth another look.
Remember, you only need one applicable SIN to make your whole Schedule TDR, so you can include a TDR applicable SIN in your offer for a GSA Schedule or submit an Add SIN mod to add a SIN to your Schedule if you are already a GSA contractor. In doing so, you will secure the opportunity to opt into TDR. If you did not find any relevant TDR applicable SINs to your company, don’t give up hope. GSA has been slowly rolling out the TDR program to more and more SINs over the years, so there is always a possibility that a SIN relevant to your company may be added in the future.
Opting into TDR as Part of a New Offer
If you are a prospective contractor submitting an offer for a GSA Schedule to GSA through eOffer, the process to opt into TDR is simple. All that is required is to include a TDR SIN in your list of proposed SINs when filling out eOffer and select that, yes, you do wish to opt into TDR when prompted. If you take these steps, you will not be required to fill out any CSP data in eOffer and your Schedule will automatically be opted into TDR when it is awarded. This means you should start tracking transactional data as soon as the Schedule is awarded.
Opting into TDR for Current Schedule Holders
Current GSA Schedule holders are able to opt into Transactional Data Reporting by submitting a “Participate in TDR” modification in eMod once they have a TDR applicable SIN. This is a terms and conditions modification and requires submission in the eMod system.
In terms of files that need to be submitted with this mod, you only need three per GSA’s modification guide: a cover letter, a copy of the most recently approved Price Proposal Template and/or Product/Services Plus File, and a copy of the current Commercial Price List and/or Market Rate Sheet. Once you have these files ready, you can submit the modification for review by GSA. GSA has provided step-by-step instructions on how to complete this request.
After the modification is awarded, you will be opted into TDR as of the first date of the next quarter after the modification is approved. For example, if the modification is approved on April 20th, you would complete a final quarterly report by July 30th for the period from April - June. Your first monthly sales report would be for the month of July and would be due by August 30th.
In addition to tracking transactional data starting on July 1st, this is also the date you would be free from tracking your CSP and worrying about the Price Reductions Clause. If you have not yet set up your accounting software to pull the data for the required fields in the TDR template, which can be downloaded from the FAS Sales Reporting Portal, the time between when the mod is approved and the first date of the next quarter is a great time to do so.
You Have Opted into TDR—Now What?
One important thing to note is that opting into TDR is for the lifetime of the contract. This means that once you opt into TDR, you cannot change your mind and opt out. It is only one way, so while it is worth it for many contractors, you will want to make sure you are prepared for the additional sales reporting requirements before you sign up for it.
Armed with this knowledge, I hope you are able to make a decision about whether or not TDR is the best option for your company. However, if you need further guidance, please feel free to reach out to Winvale! Our team of experts would be happy to discuss the pros and cons of TDR and guide you through the process of opting into this exciting program.
