Proposed GSAR Transactional Data Rule May 18, 2015

Transactional Data Proposed Rule Published March 4 Contractors to report transactional data from orders and prices paid by ordering activities FSS contract and GSA non-FSS contract orders (not VA) Report transactional data at the order and BPA level to GSA monthly 1. Contract or BPA Number 7. Unit Measure (each, hour, case, lot) 2. Order Number/Procurement Instrument Identifier (PIID) 8. Quantity of Item Sold 3. Non Federal Entity, if applicable 9. Universal Product Code (UPC), if applicable 4. Description of Deliverable 10. Price Paid per Unit 5. Manufacturer Name 11. Total Price 6. Manufacturer Part Number  

Transaction Data Survey Results Approx 70 member company responses Small, medium and large businesses 98% GSA Schedule contractors 42% have GWACs through GSA One quarter small business Based on survey estimated total cost to implement transactional data is $814,700,534—30 times GSA’s estimate of $24 million

Transactional Data Reporting- Comments The proposed rule is not reasonably constructed to achieve GSA’s stated objectives of: Improving GSA’s ability to conduct meaningful price analysis and reduce price variability Validating fair and reasonable pricing Improve GSA customers ability to compare prices A system that continually drives down prices without regard to terms and conditions negatively impacts the supplier base, particularly small businesses, and ultimately the Federal customer The proposed rule does not adequately protect confidential commercial information Transactional data is already available from government and independent commercial sources

Transactional Data Resources Coalition Public Comments Comment Summary GSA IG Public Comments Off the Shelf radio interview with former GSA IG Brian Miller Friday Flash Legal Corner by Jonathan Aronie Friday Flash Legal Corner by Brian Miller

Section 508 NPRM Accessibility standards for ICT (Information and Communication Technology) published Feb 27 Applies to ICT developed, procured, or used by Federal agencies Conformance through VPAT Draft standards Ch 3 and 4 (Functional performance criteria and Hardware) Applicability of requirements to MFDs (e.g. 402 Closed Functionality) US Access Board interested in committee feedback Comments due May 28

Upcoming Events Webinar: Big MACs - Inside the Government's Super-sized Opportunities Bloomberg May 28 | 2:00- 3:00 p.m.

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