Reporting Requirements of GSA’s Proposed Transactional Data Reporting Rule

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The recent General Services Administration proposed rule to require reporting of transactional data for GSA multiple award schedule contracts, GSAR Case 2013-G504, proposes phasing in the sales reporting requirement, beginning with a pilot affecting the Federal Supply Service (FSS) multiple award offerings “where obtaining such data has the greatest potential impact to reduce price variability and help agencies secure better value for the taxpayer through category management.” According to the proposed rule, upon completion of the pilot program, GSA will then decide whether to extend the transactional data reporting requirement to all GSA Schedules. It is important to note that the proposed rule does not apply to the VA Schedules for medical products and services.

The proposed rule requires reporting of “contract sales,” which are defined as sales of items listed on the GSA contract and sold to authorized users.

The proposed rule would require reporting the following transactional data within 15 calendar days of the end of each monthly reporting period:

(i) Contract or BPA Number;

(ii) Order Number/Procurement Instrument Identifier (PIID);

(iii) Non Federal Entity, if applicable;

(iv) Description of Deliverable;

(v) Manufacturer Name;

(vi) Manufacturer Part Number;

(vii) Unit Measure (each, hour, case, lot);

(viii) Quantity of Item Sold;

(ix) Universal Product Code (UPC), if applicable;

(x) Price Paid per Unit; and

(xi) Total Price.

The proposed rule states that “data submission will be enabled through multiple electronic interfaces . . . . The goal is to make the reporting process as streamlined, secure and efficient as possible for contractors, requiring them to submit only the transactional data GSA cannot access via other means (e.g., GSA contract management systems or Federal reporting systems such as the System for Award Management (SAM) or the Federal Procurement Data System (FPDS)).” GSA notes that none of its existing systems can capture enough transactional data to be useful for analysis, and that one alternative would be upgrading FPDS “to collect transactional data. However, this would require Federal Acquisition Regulation revisions, tens of millions of dollars in system changes, and years to implement.” By contrast, GSA estimates the burden for contractors to set-up transactional data reporting “to average a one-time initial set-up burden of 6 hours” and that “thereafter, the [average] monthly burden estimate to report data is approximately .52 of an hour or 31 minutes.”

As we reported in our March 9 blog, GSA will be hosting a public meeting for comment on the proposed rule on April 17th. Additionally, comments can be submitted online at (Reference GSAR Case 2013-G504), via facsimile at (202) 501-4067, or via the postal service. All comments must be received by May 14, 2015.

About Robert Howe

As a managing consultant in Aronson’s Government Contract Services Group, Rob Howe guides GSA Schedule efforts for clients across a wide variety of industries. With more than 14 years of direct experience with GSA contracts, he assists his clients with contract preparation, renewals, and ongoing contract management, administration, and compliance support. Prior to joining Aronson, Rob worked on government contract bid protests, qui tam, false claims, and other litigation before boards of contract appeals, the federal claims courts, and the U.S. Supreme Court. As an expert in the field, he has also worked on many publications in government contracts law. Rob received his bachelor’s degree from Macalester College in Minnesota and ABA-approved paralegal certification from George Washington University in 1986.

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