[URGENT ALERT] GSA Releasing Transactional Data Reporting Rule 6/23

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On June 23rd, GSA will release its final rule regarding the Transactional Data Reporting (TDR) pilot program that could radically change how the government negotiates pricing on the GSA Schedules and orders thereunder. Under the pilot, certain Schedule holders will be required to provide monthly sales reports, including prices paid information, to serve as the basis for pricing negotiations. In exchange, GSA will eliminate the requirements for those contractors to provide a Commercial Sales Practices (CSP) format and track commercial prices to a Basis of Award customer for price reductions.

GSA will implement the TDR pilot using a phased approach. Eight GSA Schedules are included. They are listed below in the order in which they will be added to the program, beginning in August and continuing through the end of 2016 –


GSA anticipates the TDR pilot will last approximately three years, and it must be in place for at least one year before GSA can expand the program to other Schedules / SINs or make it permanent. New offers WILL automatically be subject to TDR, but current contractors can choose whether to participate. Existing Schedules holders will NOT be required to participate unless their contract renews during the pilot.

GSA will incorporate the TDR clause into affected Schedules via the refresh and mass modification process. The TDR requirement will commence on the first day of the quarter following the acceptance of bilateral mass modification A509.

Aronson will be providing more detailed information about the TDR pilot over the next few weeks as we work through the 185-page final rule. You can also find useful information, including an FAQ, on GSA’s Interact website. Please contact Aronson if you have any specific questions about this major change to the GSA Schedules Program.

About Jennifer Aubel

Jennifer Aubel is a Principal Consultant in Aronson LLC’s Government Contract Services Group. She is responsible for leading clients successfully through the GSA lifecycle, from obtaining a new GSA Schedule contract through administering ongoing contracts. She works closely with clients to custom-tailor GSA Schedule solutions that meet current and future organizational needs by developing scope and pricing strategies, maintaining contract compliance, providing audit support, and improving the profitability and versatility of the GSA Schedule contract. Additionally, Jennifer frequently speaks on GSA Schedule topics at both Aronson and industry-sponsored events and is an active member of the National Contract Management Association. Ms. Aubel has over fifteen years’ experience in the Federal Contracting market, working for both contractors and as a consultant to GSA Schedule contract holders. Prior to working with Aronson, she managed a multi-million dollar GSA program comprised of six GSA Schedule contracts with more than 10,000 contract line items. She also managed a team that developed and delivered specialized training on the GSA Schedules Program to small businesses across the country. Jennifer graduated summa cum laude from the University of Maryland, University College with a Bachelor of Science Degree in Legal Studies.

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