Transactional Data Reporting
On June 23, 2016, the U.S. General Services Administration (GSA) published a General Services Administration Acquisition Regulation (GSAR) final rule requiring vendors to report transactional data from orders placed against certain Federal Supply Schedule (FSS) contracts,Governmentwide Indefinite-Delivery, Indefinite-Quantity (IDIQ) contracts, and Government-wide Acquisition Contracts (GWACs). Under the MAS Program, TDR was implemented as an optional pilot under specific Schedules and Special Item Numbers (SINs).
If you choose to opt into TDR, you are NOT required to provide Commercial Sales Practices (CSP) disclosures identifying discounts, terms, and conditions offered to your commercial customers that equal or exceed the discounts, terms, and conditions offered to GSA. Additionally, the requirement to monitor and report price reduction violations through the Price Reductions clause is removed.
Contractors reporting under the TDR rule must report the following line-item data on a monthly basis:
- Contract/BPA Number
- Delivery/Task Order Number/Procurement Instrument Identifier
- Non-Federal Entity
- Description of Deliverable
- Manufacturer Name
- Manufacturer Part Number (MPN)
- Unit Measure
- Quantity of Item
- Universal Product Code (UPC)
- Price Paid Per Unit
- Total Price
The following table lists TDR eligible SINs.
|Facilities||238320, 541690E, 561730|
|Facilities||322291, 326119, 339994, 333318F, 339113G|
|Facilities||311423, 333241, 335220, 336999, 332215T, 333415REM|
|Furniture & Furnishings||314110SBSA, 334110, 321918|
|Furniture & Furnishings||3FURNISH|
|Industrial Products and Services||325611, 325612|
|Industrial Products and Services||332510, 333112, 532310, 332510C, 332510S, 333TOOL|
|Industrial Products and Services||314120, 324110, 324191, 325320, 325998, 325998W, 335220D, 335220E|
|Information Technology||54151, 511210|
|Office Management||334310, 334290OS, 334511T, 541990AV|
|Office Management||339940, 339940OS4, 339940SVC, 339940OVER|
|Professional Services||541330ENG, 541330EMI, 541420, 541690, 541990, 541713, 541714, 541715, 541715AIR, 541715APM, 541720|
|Scientific and Management Solutions||541380|
*These SINs may only be awarded and used in conjunction with other TDR-eligible SINs.
The following table outlines the requirements for TDR and non-TDR offers.
Offer and Award Requirements
|Traditional Offer and Award Requirements
|CSP Disclosure||N/A||CSP disclosure must be submitted with the offer, certain modification requests, and may be required prior to exercise of options|
|MFC/BOA Information||N/A||Must be submitted with offer and with certain modification requests|
|MFC/BOA Identified at Time of Award||N/A||MFC/BOA must be identified at time of award|
|MFC/BOA Discount Relationship||N/A||MFC/BOA price/discount relationship is established at time of award and must be maintained throughout the life of the contract|
|Tracking of Price Reduction Violations||N/A||Contractor is required to track and report price reduction violations.|
|Evaluation Criteria||Offer is evaluated in accordance with GSAR 538.270-2.||Offer is evaluated in accordance with GSAR 538.270-1.|
|Transactional Data Reporting||Contractors are required to report information on 11 transactional data elements GSAR 552.238-80 ALTERNATE I||N/A|
|Transactional Data Reporting Frequency||Transactional data reporting is required on a monthly basis, due 30 days after the end of each month.||N/A|
|Non-TDR Contract Reporting Frequency||N/A||Contractors are required to report total aggregate contract sales, by SIN, on a quarterly basis, due 30 days after the end of each quarter.|
|IFF Remittance Cycle||IFF must be remitted no later than 30 days after the end of each business quarter.||IFF must be remitted no later than 30 days after the end of each business quarter.|
Notes For New Offerors:
- If your offer is inclusive of a TDR Pilot SIN, your firm is eligible to participate in the TDR Pilot. If a TDR pilot SIN is included in your offer along with non-TDR SIN(s) and you elect to participate in TDR, then the entire contract will be subject to TDR, and the PRC tracking and CSP disclosure requirements are removed for the entire contract. Participation in the TDR Pilot is voluntary for all offers.
- Once the offeror selects whether or not to participate in TDR and the choice is entered within the eOffer system, the decision is final and cannot be changed in the eOffer system.
- In the event that an offeror elects to participate in the TDR pilot, but no TDR-eligible SINs are identified during offer evaluation, then the offer will either be rejected or withdrawn. A contract cannot be awarded under TDR without at least one TDR-eligible SIN.
Notes For Existing Contractors Submitting Follow-On Offers:
- If an existing contractor submits an offer for a follow-on contract, the contractor will be given the opportunity to elect whether to participate in TDR when the new offer is created in eOffer. Contractors who intend to hold “dual” contracts (i.e., leave the existing contract open until it expires and also have a new Consolidated contract) must have the same TDR status for both contracts.
- If the contractor intends to have the existing contract canceled immediately upon award of the follow-on contract, the contractor may elect to change its TDR participation upon submission of the new offer. In cases where the contractor has changed its TDR participation in its new offer, the GSA offer evaluator will presume that it is the contractor’s intent to have the existing contract be canceled immediately upon award of the new contract, and will cancel that contract accordingly.