As we are now halfway through the government fiscal year, it’s important to review changes to the GSA Multiple Award Schedule (MAS). One of the key updates is that GSA made Transactional Data Reporting (TDR) mandatory for all contractors with the release of MAS Solicitation Refresh #31 in April. Before Refresh #31, contractors without TDR-eligible Special Item Numbers (SINs) fell under the Commercial Sales Practices (CSP) reporting structure and were required to monitor their compliance with the Price Reductions Clause.
It’s important for CSP contractors to understand how to grow their contract without the constraints of the Price Reductions Clause once they begin participating in TDR. In this blog, we’ll explain the Price Reductions Clause, discuss what the removal of this clause means, and how to set up your GSA Schedule for success under TDR before its implementation.
What is the Price Reductions Clause?
The Price Reductions Clause, or General Services Acquisition Regulation (GSAR) 552.238-81, requires CSP contractors to disclose the specific customer or a category of customers (e.g., state and local governments, nonprofit institutions, etc.) that received their best prices and discounts within the previous 12 months.
This unique customer or customer class is considered the contractor’s Most Favored Customer (MFC), and in most cases, will be the customer used as the contractor’s Basis of Award (BOA) customer. The discount the BOA customer receives is used to establish a discount relationship with the contractor’s GSA Schedule prices that will need to be monitored for compliance over the duration of the contract.
If this discount relationship changes (i.e., the BOA customer receives a more favorable price commercially), the Price Reductions Clause requires the contractor to lower their GSA Schedule prices accordingly, which we’ll discuss more in the next section.
There is a version of the Price Reductions Clause, GSAR 552.238-81 (DEC 2025) (GSAR DEVIATION) that applies to TDR contractors in the MAS Solicitation; however, this clause is for voluntary contractor-initiated price reductions or GSA-requested price reductions. These temporary or permanent price reductions are not associated with a BOA customer. In this blog, references to the Price Reductions Clause refers to the non-TDR version.
How Does the Price Reductions Clause Impact CSP Contractors?
We’ve discussed what the Price Reductions Clause is, so let’s focus on an example next:
GSA and an offeror under CSP had agreed prior to the offeror’s GSA Schedule award that the government would receive a 5% discount for all contract offerings. The offeror’s BOA customer received a 2% discount, so the government would receive an additional 3% discount. If the contractor decided to change the discount given to their BOA customer in their commercial work from 2% to 7%, they must alert their assigned Contracting Officer (CO) to the price reduction and reduce their GSA Schedule prices by 5% to maintain the 3% delta in the BOA customer to GSA discount relationship.
The Price Reductions Clause wouldn’t apply if a contractor lowered their prices for their BOA customer for a commercial project exceeding the maximum order limit associated with their GSA Schedule contract.
Commercial Sales Practices (CSP) vs. Transactional Data Reporting (TDR)
Before we dive into the Price Reductions Clause any further, let’s review the two reporting structures prior to Refresh #31 crucial to understanding the impact of this clause: Commercial Sales Practices (CSP) and Transactional Data Reporting (TDR).
Commercial Sales Practices (CSP)
Offerors subject to CSP were required to disclose the discounts, concessions, and delivery terms provided to their commercial customers within the previous 12 months to determine their MFC and BOA customer that would be used to monitor compliance with the Price Reductions Clause as a contractor. This disclosure was completed in the CSP-1 form submitted with their offer.
CSP offerors were also required to provide supporting documentation for their proposed prices for each service or product. This documentation could be publicly available commercial catalogs or price lists, invoices, contract-awarded pricing, or active quote sheets. After contract award, CSP contractors report their total sales received per SIN each quarter in the FAS Sales Reporting Portal (SRP) by the 30th of the month following the end of that reporting quarter.
New offerors will now submit their proposals in accordance with TDR practices, which are explained next.
Transactional Data Reporting (TDR)
Under TDR, contractors do not disclose CSP information and are not subject to the Price Reductions Clause. Instead, TDR contractors report their GSA Schedule sales monthly on up to 19 data fields in the Sales Reporting Portal (SRP), providing GSA with more detailed insight into the services and products being purchased and their prices across the entire MAS contract vehicle.
Pricing support is not required for new offerors or existing contractors submitting their proposal or modifications under TDR due to the availability of existing market data and other government sources in accordance with Federal Acquisition Regulation (FAR) Subpart 15.4 (GSA Class Deviation RFO-2025-15). However, it’s still a good idea to submit or have readily available supporting pricing documentation to justify your proposed MAS rates. Your reviewing CO is allowed to request pricing support to assist in their determination of fair and reasonable pricing.
Expanding Your GSA Schedule Without the Price Reductions Clause
As the Price Reductions Clause will no longer be applicable to GSA MAS under TDR, previously CSP contractors will have increased flexibility in the products and/or services they can add to their contract’s available offerings. If you were hesitant to add items to your GSA Schedule that you may discount significantly to certain commercial customers, and thus, would then be required to add the items to your contract at that same or a better discount, your current contract offerings may be limited.
Now, with the removal of the Price Reductions Clause, you can expand your labor categories, products, fixed-price services, training courses, or other offerings through Addition Modifications without worrying about monitoring the discount relationship between your commercial customers and GSA prices. There are varying requirements associated with an Addition Modification depending on whether you are adding products or services to your GSA Schedule; GSA’s MAS Modification Guide outlines instructions for preparing different types of contract modifications.
GSA will still expect a discount to be provided at the contract level for newly added items, but you won’t be required to match the same discount or provide a better discount than your established BOA customer received, as with CSP disclosures.
Next Steps for CSP Contractors
First, if you are a GSA Schedule contractor, whether CSP or TDR, you will need to review and accept the Mass Modification for Refresh #31 within 60 days of its release in the Mass Mods Portal. Contractors currently reporting under CSP are required to opt-in to TDR through a second Mass Modification.
Due to a system error with the effective date for TDR implementation, CSP contractors who already accepted the original Mass Modification for opting-in to TDR will receive a second TDR opt-in Mass Modification revising the TDR implementation date for CSP contractors to the first day of the next quarter following acceptance (July 1st if accepted by June 30th).
After July 1st, most CSP contractors should be transitioned to TDR, meaning at that point, the burden of monitoring your compliance with the Price Reductions Clause will be eliminated. However, this compliance action as well as CSP disclosures are still in place until July 1st or the TDR implementation effective date for your contract for CSP contractors.
Getting Your GSA Schedule Ready for TDR
Looking ahead, it’s important for CSP contractors to have a system in place to track the additional sales reporting elements associated with TDR as this differs significantly from CSP sales reporting. While the removal of CSP disclosures and the Price Reductions Clause reduces a few compliance burdens for contractors, there will be an adjustment period as you begin transitioning your contract from CSP to TDR and become familiar with the expanded and more frequent TDR reporting requirements.
Our recent webinar provides more information on TDR, and our consultants are also always available to support your contract’s maintenance and compliance requirements.
