GSA Initiates New Pilot Program for Transactional Data Reporting
On June 23rd, 2016, the General Services Administration initiated a new pilot program for the new Transactional Data Reporting Rule (TDR) initiative. Through TDR, GSA aims to replace the existing 72A Sales Reporting System portal with a new portal to capture transactional data throughout all Federal Supply Schedule contracts, Multiple Award Schedule Contracts, Governmentwide Acquisition Contracts (GWACs), and Indefinite-Delivery Indefinite Quantity contracts (IDIQ). The rule requires that all vendors report the price for which the federal government has paid for an item(s) or service through all GSA acquisition vehicles. Currently Schedules 58 I and 72 for all Special Item Numbers (SINs) are the only 2 Schedules released under TDR. To view the tentative schedule of anticipated roll-outs click here.
Pros and Cons of the Transactional Data Reporting Rule
GSA notes several benefits to TDR in its publication (shown below) that not only pertain to vendors, but to agencies as well:
- The rule removes burdensome tracking and reporting supplier requirements from the price reduction clause (PRC) and commercial sales practices (CSP), when MAS contractors agree to report transactional data.
- The reduction in duplicative and inefficient disclosure requirements of PRC and CSP removes barriers for entering into the federal marketplace, particularly for small businesses.
- GSA estimates that the rule’s removal of current burdensome requirements will result in an estimated annual burden reduction of $29 million for GSA Schedule vendors participating in the TDR pilot.
- TDR enables agencies to make better buying decisions & achieve savings that can be passed on to the taxpayer, supporting the governmentwide category management initiative.
- TDR will provide an unprecedented level of transparency and insight into the federal and commercial marketplaces, harnessing tools and information previously unavailable to drive faster, more strategic, and more successful contracting actions across the federal government.
There are also a number of challenges that contractors could potentially face with TDR such as inaccurate price comparisons, product design differences that are not reflected in part numbers, and disparities in terms and conditions. Potential concerns such as these should become more evident as the pilot program roles out.
While acceptance of the TDR mass modifications are still optional, it is however strongly encouraged. TDR will be mandatory for all new offers submitted under pilot schedules and will tentatively become mandatory in the next two years. Vendors are responsible for determining whether the TDR initiative applies to their contract and if so when. Contractors and prospective contractors can participate in upcoming hosted webinars on GSA Interact and complete self-paced training modules prior to accepting the mass modification. Any questions or concerns should be brought to the attention of one’s Contracting Officer prior to acceptance.
Some of the Many Changes to Expect
The Transactional Data Reporting Rule updates and replaces several clauses regarding the Industrial Funding Fee (IFF), Sales Reporting, Price Reduction Clause and Commercial Sales Practice submission requirements. A few of the TDR required elements for report submission include: Contract or Blanket Purchase Agreement (BPA) Number; Manufacturer Name, Universal Product Code, and Manufacturer Part Number. It is imperative to note that if a contractor is a distributor of a product and not the manufacturer, it is required that the manufacturer’s part number be reported and not a self-assigned number used for business purposes. There are also several changes regarding the IFF. The GSA Federal Acquisition Service (FAS) is now allowing vendors to remit IFF payments on a monthly basis rather than quarterly. All payments will now be made on the FAS Sales Reporting Portal through www.pay.gov which will now replace the 72A portal. In addition, there are also changes as to what means of payment are acceptable. TDR now requires payments to be made via credit card, debit card, or electronic check. Paper checks will no longer be accepted as a form of payment on a general basis (the rules regarding international companies have not yet been finalized). If any refunds are made after submitting a sales report, the contractor is now responsible to remove, adjust, and re-file the report. This means that negative amounts, rounding of numbers, and adjustments to subsequent reports are no longer accepted as a way of amending a previous report.
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