Transactional Data Reporting (TDR) is becoming an increasingly important acronym to remember in the GSA Multiple Award Schedule (MAS) Program. Now the TDR Program is becoming mandatory for all GSA MAS contractors, many prospective and current contractors are shifting gears from the legacy Commercial Sales Practices to learn how to navigate TDR.
With that information, you may be asking: what is TDR? How do I transition over? 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.
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? Every month, GSA collects transaction-level data from TDR-eligible contractors through the MAS sales reporting process. Now that TDR is becoming mandatory for all contractors, it'll be the same process for all. TDR is very different from Commercial Sales Practices (CSP) legacy reporting, because you don't have to abide by the Price Reductions Clause which we'll touch more on below.
Each month, GSA Schedule contractors report on their GSA Schedule sales through the FAS Sales Reporting Portal (SRP). They are required to report on 12 data elements, and have the option to report on 4 additional metrics. The 12 elements are:
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:
Before we get too far into the transition steps, let's discuss the difference between TDR and the Commercial Sales Practices legacy requirements, so you know what's about to change.
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 under TDR. 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. This clause will go away soon with Refresh #31.
With TDR, you are required to report information on 12 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.
So, if you don't have to submit Commercial Sales Practices anymore, you may be wondering, how does GSA ensure you have "fair and reasonable" pricing? The main determining principles for "fair and reasonable" pricing are:
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 few 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.
In recent MAS Solicitation Refreshes, especially Refresh #31, GSA has steadily expanded the TDR program to all MAS contractors. TDR used to be open to only a certain number of SINs, and if yours was on the list you could opt in. Now, TDR is going to be mandatory for all contractors regardless of what SINs you are selling under. If you are affected by this, it's time to start transitioning over to TDR. We'll cover more on this below.
If you currently have an offer in for the MAS Program and you didn't previously qualify for TDR, you should withdraw your offer and resubmit under TDR requirements. If you do not eventually withdraw your offer, it’ll be rejected by GSA.
If you already hold a GSA Schedule and are now required to transition to TDR, this section is for you. The first step is, GSA will issue a “Participate in TDR" Mass Modification to all MAS contractors who have not yet transitioned. The Mass Mod date will align with the beginning of the next sales reporting quarter. You will have 90 days to go in the Mass Mod system and accept this modification once released.
Once the modification is out, the clock starts ticking on the transition timeline. For example, if the “Participate in TDR” Mass Mod is initiated in February 2026 (a likely timeframe), the TDR begin date wouldn’t be until the first date of the next sales reporting quarter which is April 1, 2026. You are required to capture transactional data beginning on the effective date of the Participate in TDR modification (in this example that would be April 1, 2026).
Price Reductions Clause liability will end on the 1st day of the next sales reporting quarter following the execution of the Participate in TDR mod.
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, 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 how to transition 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.