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.