If you’ve been researching the GSA Multiple Award Schedule (MAS) Program, or have found yourself in a position where you need to quickly familiarize yourself with GSA acronyms listed on your GSA Schedule, then you may have come across the term Transactional Data Reporting (TDR).
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 me explain everything you need to know about Transactional Data Reporting.
Transactional Data Reporting (TDR) is a GSA Schedule pilot program that was first announced in March 2015. In 2016, it was incorporated into the General Services Administration Acquisition Regulation (GSAR) per GSAR 538.270-2, and then rolled out in full or in part, to 8 Schedules. Since the GSA Schedules Consolidation, TDR currently applies to only some of GSA's 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 equip the government’s acquisition workforce with the information needed to make data-driven decisions that save taxpayer dollars. The 11 data elements collected on each transaction are:
Through TDR, you are required to report the GSA sales of your products and services once a month through the Federal Acquisition Service Sales Reporting Portal (FAS SRP). You must also report on the 11 data elements listed above which may seem like a substantial amount, but you are exempt from submitting a Commercial Sales Practices form and you are not subject to the Price Reduction Clause.
If the TDR program sounds like it would be a good option for your organization, then you’re likely wondering if your contract qualifies. TDR is currently only open to 65 of the 300+ SINs, however, GSA does have a plan to make TDR accessible across all SINs. There is no set date for this yet and we have seen the timeline get pushed, but we will continue to monitor for any updates. If you have one SIN with TDR eligibility, then you can opt into TDR.
If you are a current Schedule holder and you are not sure if your contract is TDR, the easiest way to tell 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.
In order to determine if Transactional Data Reporting is a good fit for your Schedule, let’s discuss the difference between TDR and the Commercial Sales Practices legacy requirements:
As mentioned earlier, Commercial Sales Practice (CSP) disclosures 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 that you (the contractor) must 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 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, 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 recently, 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.
Is TDR a Good Fit for My Company?
TDR is not for every business. 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, you should weigh the pros and cons of each method and see which one will work better.
We don’t expect you to understand everything about TDR right away. If you have any questions about TDR whether its your eligibility or how to report, we would be happy to help. If you think TDR is a good fit for your company and you would like to switch from Commercial Sales Practices to TDR, one of our consultants can help you make the transition to TDR and assist with monthly sales reporting.