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An Invitation to Recommend Performance Measures for TDR

This week, I attended the Committee for a Responsible Federal Budget’s event focusing on economic policy and the coming Presidential Transition.  Entitled, “How Would Clinton and Trump Manage Our Money? A Conversation with the Candidates’ Economic Advisors,” the meeting was a robust, wide-ranging discussion of economic policies, performance measures, and goals.  As the economic advisors addressed their respective candidates’ economic goals and measures of performance, I found myself relating the discussion to GSA’s portfolio of interagency contract vehicles and the performance measures/goals of the Transactional Data Reporting (TDR) pilot.

In the preamble to the TDR rule, and in response to questions regarding the rule’s implementation submitted by the Coalition, GSA reaffirmed its plans to use four TDR performance measures: (1) competitive pricing; (2) increased sales volume; (3) small business participation; and (4) macro use of transactional data by category managers.

According to its responses to the Coalition’s questions, however, GSA is not tracking/measuring the direct and indirect costs of implementing this rule for government and industry.  For example, when the Coalition specifically asked whether it planned “to assess whether the pilot has increased or decreased burden to contractors in determining if the pilot has been successful,” GSA responded that it “will evaluate the pilot based on the metrics delineated in the rule, but will continue to be mindful of the burden placed on its stakeholders.”  See Q&A No. 64.

Throughout the TDR rule-making process, GSA’s industry partners repeatedly raised questions and concerns regarding the new administrative and compliance burdens associated with the proposed rule.  In response, GSA eliminated the Commercial Sales Practice (CSP) in addition to the Price Reduction Clause (PRC), maintaining that this elimination reduced contractor burden as compared to the TDR rule.  Despite the elimination of the CSP and PRC, however, feedback from Coalition members continues to raise questions regarding the estimated burdens associated with TDR, so much so that, at the request of our members, the Coalition is analyzing the burden estimate presented in the final rule.

It is troubling that, in assessing the viability and utility of TDR, GSA would not seek to validate its contractor burden estimates or track internal implementation and administrative costs.  From the standpoint of fundamental best business practices, in order to determine the benefits of the pilot, GSA’s benefits analysis actually must identify, measure, and compare pre- and post-pilot direct and indirect costs.  This assessment is critical.  First, the impact that TDR will have on GSA, its customer agencies, and its contractors is unknown, and thus, this data will serve as a tool to help GSA decide whether the TDR really benefits agencies and the taxpayers.  Second, and perhaps more important, the failure to identify, measure, and compare pre- and post-pilot direct and indirect costs of the pilot strikes at the credibility of the rulemaking process.  It gives the impression that the “pilot” is nothing more than an intermediate step to make permanent the TDR no matter the actual costs to government and industry, or whether the targeted users of the data find it valuable.

As such, we are gratified by GSA’s invitation to provide recommendations regarding additional TDR performance measures, and we commend the agency in its efforts to “get things right.”  In furtherance of its work, the Coalition invites stakeholders from across the procurement community to share their thoughts/suggestions regarding both metrics and mechanics for measuring TDR performance.  Please send your comments/suggestions to Sean Nulty at

We look forward to your input and continuing the dialogue with GSA and stakeholders across the procurement system on performance measures that holistically and effectively assess the impact of TDR on customer agencies, GSA, and GSA’s industry partners.

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