Transactional Data Reporting (TDR) is becoming an increasingly important acronym to remember in the GSA Multiple Award Schedule (MAS) Program. Now that GSA is ending the TDR pilot program and expanding it to several contractors, you may be subject to or required to opt into the program soon.
With that information, you may be asking: what is TDR? Is my contract subject to TDR? What are the requirements for TDR? These are all valid questions, and we get them a lot when it comes to reporting GSA sales. Let's cover everything you need to know about Transactional Data Reporting.
What is Transactional Data Reporting (TDR)?
Transactional Data Reporting (TDR) was first introduced in March 2015 as a pilot program. In 2016, it was incorporated into the General Services Administration Acquisition Regulation (GSAR) per GSAR 538.270-2, and then rolled out in slowly to GSA Schedule Special Item Numbers (SINs).
TDR provides market intelligence to GSA and its partner agencies, by collecting transaction-level data on products and services purchased using the GSA MAS Program. The intent is to provide the government’s acquisition workforce with the information needed to make data-driven decisions that save taxpayer dollars.
How is TDR used by GSA Schedule contractors? GSA is one form of GSA Schedule sales reporting. Every month, GSA contractors who are opted into TDR report their GSA Schedule sales. TDR is very different from the other form of reporting, Commercial Sales Practices (CSP), because you don't have to abide by the Price Reductions Clause which we'll touch more on below.
TDR Sales Reporting
Each month, GSA Schedule contractors report on their GSA Schedule sales through the FAS Sales Reporting Portal (SRP). They are required to report on 11 data elements, and have the option to report on 4 additional metrics. The 11 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
In the last year, GSA has added four additional optional metrics that are being tested. They are currently optional, but as GSA expands the program they could become mandatory. The four elements are:
- Order Date
- Ship Date
- Zip Code Shipped To
- Federal Customer
Recent TDR Changes
In recent MAS Solicitation Refreshes, especially Refresh #27, GSA has greatly expanded the TDR program. In Refresh #27, GSA made TDR mandatory for all product SINs and the Cloud SIN (518210C). This is the first time the program has been made mandatory for any contractors, and it effectively ends the pilot program.
If you are affected by this, it's time to start transitioning over to TDR. GSA announced that September 30, 2025 is the deadline for contractors to switch over from CSP to TDR. The Price Reductions Clause liability (which is the pricing rule you have to follow under CSP) is a little unclear right now. In the GSA Refresh #27 webinar, GSA said once the “Participate in TDR” modification is complete, you will no longer be tethered to the clause (if you are opted into TDR by then). We will update you as we hear more information. GSA will post more updates on the TDR page on GSA.gov.
Is My Contract Subject to Transactional Data Reporting?
You’re likely wondering if your contract qualifies (or if it's now mandatory for you). TDR is now open to ALL product SINs and some additional services SINs, but not every contractor can opt in yet. GSA has a plan to eventually expand it to all contractors soon as mentioned above. There is no set date for this, but we've seen GSA make more strides in this recently, so we can expect the timeline to move faster than originally anticipated.
If you have a product SIN and/or hold the Cloud SIN (518210C), then TDR will become mandatory for you. If you don't hold any of these SINs, but still want to see if you can opt in, then we suggest you check out the TDR list of SINs on GSA's site. If GSA hasn't updated it fully from Refresh #27 yet, we suggest you cross reference it against the recently added list of SINs.
Another way to do this is to log-in to GSA’s Sales Reporting Portal to see if you’re required to report on monthly basis. Once you log-in, from the landing page you’ll see a column titled “Current Reporting Frequency." If your frequency is “quarterly,” your contract is not TDR. A “monthly” frequency indicates that your contract is TDR.
It's important to note if you have one SIN with TDR eligibility, then you can opt into TDR.
Differences Between Transactional Data Reporting and Commercial Sales Practices
Let's discuss the difference between TDR and the Commercial Sales Practices legacy requirements.
As mentioned earlier, Commercial Sales Practice (CSP) disclosures are not required with TDR – these are the discounts and concessions offered to your commercial customers. You do not have to report your Most Favored Customer (MFC) and your Basis of Award (BOA) customer either. With Commercial Sales Practices, you must identify a MFC (who gets your best pricing and pricing terms) and a discount relationship with your BOA customer (which is usually the same as your MFC).
You are also not subject to the Price Reduction Clause if you are using the TDR method. The Price Reduction Clause requires you to define the discount relationship with your BOA customer and any time you lower your prices for them, you must change your GSA Schedule prices so it maintains the discount delta.
With TDR, you are required to report information on 11 transactional data elements mentioned above (and the optional 4 elements) and you must report on a monthly basis instead of quarterly. Your Industrial Funding Fee (IFF) payments are still due quarterly on the 30th day of January, April, July, and October like with Commercial Sales Practices, but you can opt to pay them monthly.
How Do You Determine Pricing with TDR?
So, if you don't have to submit Commercial Sales Practices, you may be wondering, how does GSA ensure you have "fair and reasonable" pricing? The main determining principles for "fair and reasonable" pricing are:
- The pricing for “like and similar” goods or services on competitor contracts
- Historical market pricing
- Currently available pricing in other contract vehicles
For TDR specifically, since your MFC and BOA aren't being used, GSA uses market research to ensure the prices fits within the GSA marketplace. The General Acquisition Services Manual (GSAM Change 171 GSAR Case 2019-G503) states, "If the Contracting Officer cannot determine the prices offered to be fair and reasonable based on the data described in 538.270-2(c)(1), perform market research to compare prices for the same or similar items in accordance with FAR 15.404-1(b)(2)(vi)."
It's important to note that in the last 2 years, GSA made some changes to how the market threshold is calculated for contractors who offer Commercial Off the Shelf Products. This change was made to help better represent the commercial marketplace and guarantee the best value for federal customers.
Preparing for the TDR Transition
While eliminating the Commercial Sales Practices and the Price Reductions Clause may make sales reporting much easier for you, TDR reporting is more frequent and requires a fair amount of detail. So, if you are planning to opt into TDR or are required to do so, we suggest you start transitioning your sales reporting practices sooner rather than later.
Of course, there's always the option to get help with your TDR transition and monthly reporting. If you have any questions about TDR, whether its your eligibility or how to report, we would be happy to help. One of our expert consultants can help you make the transition to TDR and assist with monthly sales reporting.
