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GSA’s Transactional Data Reporting Pilot: A Thoughtful Way Forward

On April 27th, GSA announced that the Transactional Data Reporting (TDR) Pilot was eligible for expansion in the Multiple Award Schedule (MAS) program.  As part of the announcement, GSA provided the latest performance results for the pilot.  The FY20 results showed steady progress, with data completeness, contract-level pricing, and small business metrics all exceeding targets.  GSA concluded that “[w]hen TDR is used, government prices are lower, the reporting burden on contractors is reduced, and small businesses generate stronger sales growth.”

To be clear, during the initial public rule making for TDR the Coalition raised questions and concerns regarding the mechanics of the pilot.   As the pilot has progressed, however, it has become apparent that TDR has had a positive impact on the MAS program.  TDR reduces administrative burdens and risk on MAS contractors as compared to the outdated, anti-competitive legacy MAS pricing policies, especially the Price Reduction Clause (PRC).  Reducing contract administration burdens, in turn, reduces barriers to entry for commercial firms, especially small commercial firms, providing increased competitive opportunities for contractors in meeting customer agency needs.  Reducing burdens also provides customer agencies an increased level of efficient and effective access to new commercial capabilities.

Significantly, TDR aligns with the MAS statutory and regulatory competitive ordering procedures.  TDR recognizes that pricing and best value are driven by competition at the order level for agency-specific requirements.  Reporting data on real time, competitive transactions will assist government and industry in improving overall management operations and procurement planning.  In stark contrast, the legacy pricing policies, especially the PRC, are at cross purposes with the competitive ordering procedures, focusing significant government and contractor resources on administrative oversight rather than on competition for agency requirements.  The legacy MAS pricing policies are not only a costly drain on MAS’s competitive marketplace, but also a restraint of trade, restricting MAS contractors’ ability to compete in the commercial market.  These costly, administrative burdens of the legacy pricing policies fall especially hard on small businesses.

As the April 27th announcement notes, work still needs to be done.  Training contracting officers on price analysis and the sound, beneficial use of transactional data is critical to expansion of the pilot, and it is gratifying to see GSA’s focus in this regard.  GSA will be refining and considering further the ability of MAS contracting officers to leverage TDR in lieu of the legacy pricing policies and the PRC.  GSA also will consider and improve the impact of expanded data collection and GSA’s ability to leverage the data it collects.  Finally, GSA will be assessing and considering the impacts of TDR on current and future MAS contractors.

GSA should be commended for its thoughtful, focused approach to TDR expansion.  Coalition members look forward to working with all stakeholders on the expansion of TDR across the MAS program.

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