1. Transactional Data Reporting
June 2016

2. Transactional Data Final Rule
Contract/BPA Number
Delivery/Task Order Number/Procurement Instrument Identifier (PIID)
Non-federal Entity
Description of Deliverable
Manufacturer Name
Manufacturer Part Number (MPN)
Unit Measure
Quantity of Item
Universal Product Code (UPC)
Price Paid Per Unit
Total Price
Published June 23, 2016 (GSAR Case 2013-G504)
FSS contract and GSA non-FSS contract orders (not VA)
Contractors to report transactional data from orders and prices paid by ordering activities
Monthly reporting

3. Modifications based on Public Comments
Elimination of the CSP disclosures in addition to PRC basis of award tracking customer
Updated burden estimates
Implementation through voluntary pilot
Extended transactional data reporting deadline to 30 days after end of month vs 15 days
Industrial Funding Fee (IFF) payments allowed quarterly

4. Transactional Data Reporting and IFF
TDR on monthly basis:
Report within 30 calendar days after the last day of month
Based on either issuance of an invoice or receipt of payment
72A Sales Reporting System
IFF payments quarterly
Due 30 days after quarter

5. Government Use of Transactional Data
Purpose is “to transform price disclosure and related policies” for GSA contracts
Support Category Management
Ensure offered price is competitive relative to other vendor same or similar products/services
Update GSAM pricing instructions to place greater emphasis on price analysis
Allows CO to request additional pricing information if can not determine whether price is “fair and reasonable” after assessing FSS and Governmentwide contract pricing, prices paid, and other publicly available data
GSA price instruction changes
Emphasizes the need to specifically consider
(i) offered prices on FSS contracts or Governmentwide contracts for the same or similar items or services,
(ii) prices paid, as it becomes available under this rule, and
(iii) Commercial data sources providing publicly available pricing information.
The GSAM guidance will also reiterate that the contracting officer is responsible for ensuring pricing is fair and reasonable.
If a contracting officer is unable to make this determination based on data available to them through GSA’s tools or available commercial pricing information, they will retain the right, to request additional pricing information, such as data other than certified cost and pricing data

6. Security and Protection of TDR
Transactional data in portal accessible only by authorized users
Protection in accordance with GSA IT security policies
Intent to share data to maximum extent allowable
Plan for “public data extract” to be released in upcoming Federal Register notice
The Public Data Extract would contain information that would otherwise be releasable under the Freedom of Information Act (FOIA)

7. Voluntary Pilot
Begins not less than 60 days of the final rule’s publication
Voluntary participation via bilateral contract modification for existing contractors
New contract awards and contract extensions automatic transactional data reporting
After 1 year, an evaluation will determine the future of transactional data reporting based on:
Changes in price, sales volume, small business participation, use of data by Category Managers, etc.

8. Transactional Data Pilot (Schedules/SINs)
03 FAC Facilities and Maintenance Services
51 V Hardware Superstore
58 I Professional Audio/Video
72 Furniture and Floor Coverings
73 Food Service, Hospitality, Cleaning Equipment
75 Office Products
Professional Services Schedule (only Engineering SIN)
IT Schedule 70 (only SINs: 132 8, , , , , and132 55)
Notification of launch date posted on GSA Interact 30 days in advance

9. Questions/Concerns
Is the elimination of PRC basis of award tracking and CSP disclosures enough a burden reduction to account for Transactional Data Reporting?
Will the data be used to continually drive down pricing?
How will price analysis be conducted appropriately without the associated terms and conditions?
How will GSA ensure the protection of proprietary information in the portal and in the public data extract?
How will contracting officers be properly trained on the use of transactional data in price analysis?

10. Member Feedback

11. Coalition Comments to Date

12. Coalition Response to Proposed Rule
Transactional Data Survey
Spring 2015
Written Comments
May 4, 2015
Congressional Testimony
June 25, 2015

13. Transactional Data Survey

14. Written Comments – 6 Recommendations
Compare offered prices for identical products; reject outliers
Assure that offerors are authorized resellers
Encourage contractors to update GSA Advantage!
Increase training to customer agencies
Pilot test collecting data internally
Eliminate the PRC

15. Congressional Testimony
Before the Subcommittee on Contracting and Workforce of the Committee on Small Business
Reiterated recommendations of submitted comments
Video of the testimony available here

16. Thank you