In May, GSA leadership announced the decision to make the Transactional Data Reporting (TDR) pilot program voluntary for contractors on the Multiple Award Schedules and/or Special Item Numbers (SINs) included in the pilot program. The TDR rule, published in June 2016, enables GSA to collect transactional-level data on purchases made through a GSA contract vehicle. This data provides valuable information that not only helps us craft smarter buying strategies, but allows agencies to make smarter purchasing decisions, enhances competition and gives the federal government key intelligence around buying patterns.
This new GSA Acquisition Regulation (GSAR) rule also creates tremendous advantages for the vendor community, eliminating the cumbersome Commercial Sales Practices (CSP) and Price Reduction Clause (PRC) reporting requirements, reducing compliance burdens on contractors, particularly small businesses.
We moved swiftly from publishing the rule to implementing the pilot. Pilot participation was mandatory for new contractors but voluntary for existing contractors under the pilot Schedules/SINs. However, current contractors in participating schedules were not required to join the pilot until the next option period of their contract.
Since the pilot’s inception, we’ve seen excellent voluntary participation with almost half the potential pilot population participating. GSA is altering TDR’s implementation to give new offerors and contractors approaching an option period the choice to adopt TDR. For those contractors who were previously required to accept TDR, GSA is extending them the option to execute a one-time reverse modification to undo this action and work with their contracting officer to revert back to operating under the structure and tracking requirements of the price reduction clause.
We realize this change has many critical implications, from policy and systems to training and communications. We are working steadily on these elements and are thoughtfully addressing all of its impacts. We will be communicating with all our stakeholders over the coming months as we solidify the path forward. Prior to refreshing the pilot Schedules to include this update, we posted a 30 day advanced notice on Interact outlining the change and providing an opportunity for all to comment. We are committed to ensuring the TDR pilot continues to be successful, and industry has the information they need to make informed business decisions – so stay tuned!
How We’re Evaluating the Pilot
The pilot’s evaluation criteria has also been a topic of conversation between GSA and our industry and federal agency stakeholders. The final TDR rule noted the pilot would be evaluated against a series of metrics that would include, but not be limited to, competitive pricing, increased sales volume, and small business participation, as well as macro use of transactional data by category managers and teams to create smarter buying strategies such as consumption policies. We’ve worked closely with our Senior Procurement Executive (SPE) to develop a comprehensive evaluation plan that includes metrics encompassing all these areas, as well as additional metrics incorporating employee and contractor feedback and findings from separate reviews of GSA’s effectiveness in implementing new TDR-related procedures.
GSA does not expect one single metric to solely determine the pilot’s success in improving the value we’re delivering to taxpayers. We continue to view this as a three-year pilot, with periodic reviews. The first review will take place after at least one full year of the pilot. In these reviews, our SPE will make a holistic assessment before deciding whether to continue, expand, adjust, or discontinue the TDR pilot. It’s an evolving process, intended to be adjusted as we gather lessons learned from the implementation process and meet with the Office of Federal Procurement Policy and other interested stakeholders. If the decision is made to continue TDR after the initial evaluation, we’re anticipating that TDR’s true benefits will be apparent towards the third year of the pilot as data collection matures, analytical tools are deployed to buyers, and category managers implement governmentwide buying strategies.
GSA will host a webinar for contractors to learn more about their options around TDR on September 12 at 1:00 PM EDT. Register to attend here.
If you have any questions or comments regarding TDR, please email email@example.com.