This week, the focus of this blog returns to GSA’s Transactional Data Reporting (TDR) rule. The transition from compliance with GSA’s current pricing policies to TDR is a major undertaking for both government and industry. The TDR pilot is the most significant structural and policy change in the FSS program in over 20 years.
Effective communication on key implementation issues is vital in providing for an effective pilot. GSA is in the midst of a public outreach effort to provide its industry partners with information regarding the TDR implementation schedule, operational mechanics, and policy oversight. Despite this effort, however, there is a great deal of uncertainty surrounding the pilot—uncertainty that increases risk and costs for government and industry.
On behalf of our members, this week, the Coalition submitted over sixty questions to GSA regarding TDR pilot implementation and operational mechanics. The questions can be found here. The responses to these questions will be a critical step in improving industry partners’ understanding of the TDR pilot, understanding which will reduce uncertainty in their business operations. We look forward to GSA’s responses and urge GSA to engage in a series of “in- person” industry days to engage its industry partners in a robust information exchange. Also, as noted in our cover letter to GSA, in light of the uncertainty manifested by the aforementioned questions, the Coalition recommends that GSA revise the implementation schedule for the pilot, specifically, moving the initial implementation date to January 2017.