Transactional Data Reporting (TDR) has existed for several years as a pilot program, but not every GSA Schedule contractor had to pay attention to it until now. Either your Special Item Numbers (SINs) weren’t eligible, or you chose not to opt in, but either way, it wasn’t on your radar. Things are changing now. With GSA’s Multiple Award Schedule (MAS) Refresh #31, ALL contractors are now required to switch their sales reporting over to Transactional Data Reporting. Since TDR reporting will become a monthly occurrence for you, it's important that everyone knows what TDR is and how to transition. In this blog we’ll cover what TDR is, sales reporting with TDR, and how to participate in the program.
What is Transactional Data Reporting (TDR)?
TDR is another form of GSA Schedule sales reporting. If you are currently using Commercial Sales Practices (CSP), then you are currently under the legacy reporting. TDR focuses more on transactional level data for products and services purchased through the MAS Program.
GSA likens TDR to a detailed receipt from the store versus a monthly invoice with a single number. This detailed receipt of TDR data gives GSA more information on what is really being bought and sold through the MAS Program and where the demand lies. GSA can also gather more accurate information on what prices customers are actually paying. This is a major reason GSA is moving all contractors away from the legacy reporting, which we'll discuss more in depth below.
Why is GSA Switching to TDR?
TDR has been an optional pilot program for a decade, so why is it becoming mandatory now? TDR gives GSA more detailed information than legacy reporting, and cuts costs as well as time for both industry partners and taxpayers. On the contractor side, a report from GSA said that it saves an average of 22 labors hours per contract annually over legacy reporting and sales tracking. TDR has less compliance requirements as well, which we’ll dive into more detail on below.
Additionally, TDR:
- Reduces overhead and supply chain costs
- Supports supply chain risk management
- Enables sharing of pricing insights with industry
- Cuts annual reporting costs by $3k per contract
- Serves as a resource to GSA Contracting Officers (COs) analyzing prices
How is TDR Different From CSP?
There are several ways TDR differs from the legacy Commercial Sales Practices. Overall, TDR has less compliance risks, but you do need to report your sales more often and more in depth. The biggest difference is you don’t need to worry about the Price Reduction Clause and reporting your Most Favored Customer (MFC). We’ll outline them in the table below:
Without the Commercial Sales Practices disclosure or Most Favored Customer (MFC)/ Basis of Award (BOA) mention during the award process, you might be wondering how GSA plans to evaluate your pricing. You aren’t able to just start naming prices. Your prices are evaluated in accordance with GSAM 538.270-2, which means GSA uses different methods, including:
- Prices paid information on contracts for the same or similar items
- Contract-level prices on other MAS contracts or other government-wide contracts for the same or similar items.
- Commercial data sources that consolidate and normalize prices offered by commercial vendors to the general public to compare prices for the same or similar items.
While TDR has less compliance requirements overall, you do need to be prepared to report your sales more often (monthly instead of quarterly) and track more information. Overall, TDR is estimated to save contractors time, but if you have a massive number of offerings then it can become tedious.
Participating in TDR
Whether you are a new offeror or a current GSA Schedule contractor, there are steps you'll need to take to make sure you are transitioning to TDR in a timely manner.
Current Non-TDR Offers
If you have submitted a Multiple Award Schedule (MAS) offer recently under Commercial Sales Practices and it's under review, you should withdraw your offer to submit under TDR requirements. If you don't do this, GSA will eventually reject your offer. The sooner you do this the better because it may take some time for Contracting Officers to review your offer once re-submitted.
Current Non-TDR Contractors
If you currently hold a GSA Schedule under Commercial Sales Practices, you'll need to accept the "Participate in TDR" Mass Modification once it comes out. The Mass Mod is expected to align with the beginning of the next sales quarter (we anticipate April 1, 2026). For example, if the "Participate in TDR" modification is released around the same time as Solicitation Refresh #31 in February 2026, the TDR begin date will be April 1, 2026.
Once you are in TDR, your entire contract (all SINs awarded) is subject to TDR Terms and Conditions. Although you don’t need to abide by the Price Reduction Clause, you still need to provide pricing support in both offers and your modifications. Economic Price Adjustment (EPA) requests still require the submission of Market Rates in accordance with the Modification Guidance.
Reporting Sales with TDR
TDR contractors must report monthly instead of quarterly legacy reporting requirements. The reporting process also looks different. You are required to report on 12 data elements each month, and 4 optional elements.
The 12 elements are:
- Contract or BPA Number
- Order Number/Procurement Instrument Identifier (PIID)
- Description of Deliverable (Maximum 1000 Characters)
- Manufacturer Name
- Manufacturer Part Number
- Universal Product Code (UPC)
- Unit Measure
- Quantity of Item Sold
- Price Paid per Unit
- Total Price Paid
- Non-Federal Entity Designation
- Special Item Number (SIN)
The four optional (and maybe eventually required) elements are:
- Order Date
- Ship Date
- Zip Code Shipped To
- Federal Customer
Just like with CSP, you will report your elements in the FAS Sales Reporting Portal (SRP). To gain access to the FAS SRP, a contractor must be listed on the contract in one of the following areas:
- IFF POC
- Administrative Rep
- Authorized Negotiator
There are two primary methods submit your TDR data to the FAS SRP. They are: Excel Upload and Form Entry. Form Entry is more frequently used and is usually easier for smaller vendors. If you have higher data volume, then you are better off using an excel upload into the SRP. It’s important to note that you need to report every month even if you have $0 in sales.
Sales are 30 calendar days after the end of the previous month. For example, you will report October sales on November 30th.
Your Industrial Funding Fee (IFF)
The Industrial Funding Fee (IFF) can still be paid monthly, but you can also opt to pay it quarterly at this time. There is no change to IFF rates or how you pay for it other than being able to pay it more frequently if that suits your company better.
TDR Contract Clause Changes
Once you opt into TDR, the terms and conditions of your GSA Schedule contract will change. You will have the following clauses added/removed from your contract in a TDR modification.
Contract clauses that will be added are:
- 216-70 ECONOMIC PRICE ADJUSTMENT – FSS MULTIPLE AWARD SCHEDULE CONTRACTS (SEP 1999) (DEVIATION II – JUL 2016)
- I-FSS-969 ECONOMIC PRICE ADJUSTMENT – FSS MULTIPLE AWARD SCHEDULE (OCT 2014) (ALTERNATIVE II – JUL 2016)
- 238-80 INDUSTRIAL FUNDING FEE AND SALES REPORTING (ALTERNATE I – May 2024)
- 238.81 PRICE REDUCTIONS (MAY 2019) (ALTERNATE 1 – APRIL 2014)
- 238.82 MODIFICATIONS (FEDERAL SUPPLY SCHEDULE) (JAN 2022) (ALTERNATE II – MAY 2019)
Contract clauses that will be deleted are:
- 216-70 ECONOMIC PRICE ADJUSTMENT – FSS MULTIPLE AWARD SCHEDULE CONTRACTS (SEP 1999) (ALTERNATE I – SEPT 1999)
- I-FSS 969 ECONOMIC PRICE ADJUSTMENT – FSS MULTIPLE AWARD SCHEDULE (OCT 2014)
- 238-80 INDUSTRIAL FUNDING FEE AND SALES REPORTING (JUL 2020)
- 238-81 PRICE REDUCTIONS (MAY 2019)
- 238-82 MODIFICATIONS (FEDERAL SUPPLY SCHEDULE) (JAN 2022 ) (ALTERNATE I – MAR 2020)
TDR Transition Timeline
We don't know exact dates at this time, but we anticipate the "Participate in TDR" modification to be released around the same time as Solicitation Refresh #31 in mid-to-late February. The TDR start date will align with the beginning of the next sales quarter which would be April 1, 2026. You'll be required to capture transactional data on the TDR start date (in this example it would be April 1, 2026). The Price Reductions Clause liability will end on the first day of the next sales reporting quarter following the execution of the
"Participate in TDR" modification.
Adapting to GSA Schedule Contract Changes
Under the current administration, GSA is gearing up for some major changes. In addition to TDR and other internal MAS Program updates, GSA plans to take over the procurement of most common goods and services from all federal agencies. GSA will also manage several Best-In-Class (BIC) Governmentwide Acquisition Contracts (GWACs). As a GSA contractor, it’s more important now than ever to make sure you are keeping up with the terms and conditions of your Schedule and remaining compliant. For support managing your GSA Schedule or transitioning over to TDR, we are here to help. Contact one of our consultants today.
