General Services Administration’s new Transactional Data Reporting (TDR) rule states that contractors must electronically report prices paid by the federal government for goods and services purchased through GSA acquisition vehicles. (Interact.gsa.gov). GSA intends to gain market intelligence about pricing, while improving efficiency and reducing requirements that many contractors found challenging.
TDR is significant not only because of the new reporting requirement, but also because it eliminates the long-standing task for contractors to track their Basis of Award customer’s price reductions, as the new Price Reductions clause does not include a BOA tracking stipulation.
Using a phased-in approach affecting select schedules and SINs, the TDR pilot program began August 2016. As a contractor, the specifics of what you should do depend on if you are an existing contractor or new offeror, and if your schedule is affected. See the GSA’s chart on their Interact page: https://ow.ly/j446309AOHv
Contractors submitting new offers after the solicitation refresh of affected TDR Pilot Schedules/SINs are required to accept the TDR reporting clause.
Current contractors affected by the TDR Pilot Schedules/SINs can chose to formally accept the new TDR clause and pricing disclosure through the GSA’s mass bilateral modification. The contractor may decline in the short-term; however, that schedule holder will be required to accept the TDR terms before the next option period.
The requirement for providing Commercial Sales Practices (CSP-1) documents with modification requests is eliminated once a contractor’s mass mod is accepted.
Vendors participating in the TDR pilot must pay their Industrial Funding Fee (IFF) electronically through www.pay.gov
For current schedule holders, reporting starts 30 days after the end of the first month of the quarter following adoption of the mass mod. New contractor reporting requirements start 30 days after the month of contractor award.
GSA maintains that transactional data is essential for comparing similar items; however, GSA states that it will recognize variance, and will not treat similar items from separate manufacturers as identical, as the agency also evaluates differences amongst contractors’ terms and conditions, performance and past performance.
To stand apart from other vendors, contractors should, “continue to communicate unique terms and conditions that differentiate their product or service from other competitors during the negotiation process. GSA understands that there are many unique pricing practices used by industry, and encourages communication regarding these elements.” (Interact.gsa.gov, External_TDRImplementationFAQv2).
For more information on how the TDR rule affects your GSA schedule, contact Arrowhead Solutions at arrowheadsolutionsllc.com.