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On June 13, 2016, the General Services Administration issued the final Transactional Data Reporting (TDR) rule. TDR requirements state that contractors must electronically report costs paid by the federal government for goods and services procured from GSA contract vehicles. The goals of TDR are to reduce tracking requirements, save taxpayer dollars, and gain valuable market intelligence.
The TDR pilot program began August 2016. Requirements will be phased in, affecting select schedules over the next few months. Gsa.gov’s blog states that TDR will not become permanent before the pilot program is evaluated for at least one year.
Going forward, schedule holders are no longer responsible for tracking price reductions to their Basis of Award (BOA) customer(s).
Contractors will receive a mass modification regarding the requirements. Contractors can also check interact.gsa.gov; mass mods and schedule refresh notices will be posted.
The requirement for providing Commercial Sales Practices (CSP-1) documents with modification requests is eliminated once a contractor’s mass modification is accepted. Schedule holders’ compliance requirements go into effect beginning on the first day of the quarter after acceptance of the mass mod.
From gsa.gov, “Contractors should start new reporting requirements at the beginning of the next business quarter”, as shown in the example below from gsa.gov:
Mod Accepted: Requirements Effective:
July 1st – September 30th October 1st
October 1st – December 31st January 1st
January 1st – March 31st April 1st
April 1st – June 30th July 1st
The GSA posted Public Notice-FAS-2016-01 to obtain comments regarding the public release of transactional data reported under the TDR rule per the Freedom of Information Act (FOIA). The comment period closes August 29, 2016.