When it comes to GSA Multiple Award Schedule (MAS) acquisition and post-award maintenance, contractors are often left with questions when they come across Transactional Data Reporting (TDR), wondering what it is and what the impacts on their contract are. Through TDR, contractors are required to report specific details of their sales to the government, including prices paid by government agencies for products and services. This type of reporting is chosen when eligible contractors do not submit Commercial Sales Practices (CSP) with their GSA Schedule offer, or switch over to TDR during the period of performance of their contract.
Since TDR is not open to all GSA contractors yet, our clients often want to know more about how it works and if it applies to them. So, let’s cover the ins and outs of TDR and how both contractors and government use it to their advantage.
There are many reasons an eligible GSA contractor chooses Transactional Data Reporting (TDR). First, as mentioned briefly above, you will no longer need to disclose your Commercial Sales Practices (CSP). This allows for pricing flexibility and can save you time throughout the negotiations process during GSA Schedule acquisition and during post-award activities. This reduces your compliance risk overall as well, since you don’t have to worry about disclosing your Most Favored Customer and giving them a bigger discount than GSA.
However, when it comes to sales reporting you must be prepared to report data on each transaction and report more frequently (monthly instead of quarterly). Below is a chart that goes in-depth on the different requirements for TDR and Non-TDR Contracts.
Type |
TDR offer and award requirements |
Traditional offer and award requirements (non-TDR) |
Commercial sales practice |
Not required |
You must submit a CSP disclosure with the offer or certain modification requests, and we may require it when exercising options. |
Most favored customer and basis of award information |
Not required |
You must submit the most favored customer and basis of award information with the offer and with certain modification requests. We must be able to identify this at time of award. You must maintain the MFC and BOA price-discount relationship that you established at the time of award throughout the life of the contract. |
Tracking of price reduction violations |
Not required |
You must track and report price reduction violations. |
Evaluation criteria |
We evaluate offers according to GSAR 538.270-2. |
We evaluate orders according to GSAR 538.270-1. |
Transactional data reporting |
You must report information on 12 transactional data elements within 30 days after the end of each month. See GSAR 552.238-80 ALTERNATE I for more info. |
You do not report TDR data, but must report total aggregate contract sales, by SIN, on a quarterly basis within 30 days after the end of each quarter. |
Industrial funding fee |
You must remit IFF within 30 days after the end of each quarter. |
You must remit IFF within 30 days after the end of each quarter. |
What else do contractors use TDR for? In the changing landscape of government contracting, staying ahead of your competition requires more than just delivering quality products and services—it demands insight into market trends and government buyer behavior. Contractors can visit the Vendor Support Center (VSC) to view TDR demand data reports showing contractor/manufacturer transactions for specific top selling products. This can be used to get a better view of the competition/industry and contractors can see where their products fit into the bigger picture, and possibly tailor their price list to items that customers are more likely to purchase.
However, TDR data is mostly beneficial to the government for negotiation and market research purposes, which we’ll discuss below.
TDR allows the federal government to enhance transparency and accountability across the MAS program. By requiring contractors to report specific details of their sales, such as prices paid and quantities purchased, the government can better understand what the government is purchasing and where the demand is. Real-time purchasing trends can also be analyzed to negotiate more favorable terms for the government. This method of reporting is more effective and less burdensome when it comes to pricing disclosure for both contractors and government.
At its core, the TDR program represents a shift towards greater transparency and data-driven decision-making within the federal procurement system. GSA aims to eventually fully replace the traditional Commercial Sales Practices (CSP) disclosure and Price Reductions Clause (PRC) requirements. Right now, TDR is only open to a number of SINs, which can be found on GSA’s site. Eventually (and ideally) TDR will be GSA Schedule-wide.
As TDR matures, GSA hopes to improve the dimensions of data quality, by adding extra TDR reporting fields and implementing data quality initiatives. With Solicitation Refresh #21, GSA will implement the 4 new optional fields: order date, ship date, zip code shipped to, and federal customer. Other changes include real-time validation of Manufacturer Name, Manufacturer Part Number, Unit of Measure, and Unit Price fields, and recurring contractor feedback reports. GSA’s current goal is to prioritize products-focused TDR field changes in Q3 of Fiscal Year (FY) 2024 and services-focused field changes in early FY25.
Recently, GSA talked about their additional FY2024 goals for the prioritization of TDR efforts. Ultimately, the purpose of these changes is to maximize TDR data accuracy. These include:
If you are currently eligible for TDR and aren’t opted in, we encourage you to see if it’s a better fit for your company. To learn more about CSP and TDR, check out:
That being said, if you have any questions about TDR and how it would affect your GSA contracts, feel free to reach out to Winvale and we would be happy to provide assistance in determining whether or not you would benefit from switching over to TDR.