Transactional Data Reporting for the Group 70 IT GSA Schedule

GSA’s new Transactional Data Reporting (TDR) pilot brings greater flexibility to the GSA Group 70 IT program for both new and existing Group 70 contractors and eliminates the requirement for Price Reductions Clause (552.238-75) compliance.  Contact GCSI for applicable SINs under the program and additional information.

— C. Bruce Dickinson, Principal, GCSI cbd@gov-consult.com

Transactional Data is Here: GSA Publishes Rule to Capture Data, Drive Taxpayer Savings & Reduce Burdens on Industry

November 15, 2016 | Tom Sharpe, FAS Commissioner

FAS at the Forefront |

I’ve written before that FAS, along with our industry stakeholders, has taken on the monumental task of transforming GSA’s very successful Multiple Award Schedules (MAS) program to ensure that it continues to offer the efficiency and value it was created to provide. We’ve made great strides to date, including giving our contracting professionals access to better tools and more data.

In keeping with our commitment to making the acquisition landscape easier to navigate, this summer we announced the biggest change to the MAS program in more than two decades: the introduction of the Transactional Data Reporting rule (TDR).

TDR offers great value to the American taxpayer.  Through this process, we are able to collect transactional-level data on purchases made through a GSA contract vehicle – invaluable information that not only helps us craft smarter buying strategies, but allows agencies to make smarter purchasing decisions, enhances competition and gives the federal government intelligence around buying patterns.

This new GSA Acquisition Regulation (GSAR) rule also creates tremendous advantages for the vendor community, eliminating the cumbersome Commercial Sales Practices (CSP) and Price Reduction Clause (PRC) reporting requirements, reducing compliance burdens on contractors, particularly small businesses.

As with all great change, we will all experience a period of adjustment and acclimation; but please know that we at GSA are committed to going through this process in the closest cooperation and open communication with our industry partners. GSA will continue to be transparent to industry and all of our stakeholders as we move forward in TDR data analytics and access. Please know that my door is always open, and I look forward to working with you to make an already outstanding MAS program even better for all concerned.

Category Management: Simplifying Government, Increasing Industry Opportunity

The government spends over $420 billion purchasing goods and services each year through more than 500 contracting activities dispersed among federal entities, causing contract duplication and increased administrative burdens.  In the increasingly difficult environment of doing more with less, we simply cannot afford to operate this way.

TDR fits in with the government’s move toward category management, a business model aimed at streamlining the way the public sector does business.  We’ve collaborated with our partners in the Office of Federal Procurement Policy (OFPP) to implement TDR and believe it will help us reach our goal of giving contracting officers the analyses they need to “buy smarter”.  This is a critical step forward as we enable federal contracting professionals to be faster, more strategic, and more successful within the category management framework.

Additionally, the valuable data and market intelligence collected from TDR reporting will make the Multiple Award Schedules program more attractive to federal buyers, increasing business opportunities for the industry community.

Reducing Burden and Removing Barriers to Entry

In recent discussions about the MAS program, industry voiced concerns about burdensome reporting requirements and offered suggestions for improvement.  GSA took this to heart, and implemented meaningful changes.  By accepting TDR, contractors no longer have to report CSP disclosures or comply with the hefty PRC requirement.  During our TDR pilot program, this equals an annual net burden reduction of $29 million.  Even better, these reporting requirements are eliminated prior to award, translating into burden and cost reductions for companies even before winning business off GSA Schedules.

GSA takes our commitment to socioeconomic opportunities very seriously, crafting the TDR rule with our small businesses partners in mind. Simply put, eliminating the CSP disclosures requirement in the final rule makes it easier for smaller companies to pursue Schedule contracts. In addition, unlike the PRC and CSP, TDR is not an upfront hurdle small businesses must clear so that they may do business in the federal marketplace.

We also heard that GSA has “underestimated” the burden TDR imposes.  Let me respond by saying GSA’s burden projections include a wide range of contractors, including those that have hundreds of millions of dollars in sales for thousands of items, and those with few to no sales for a relatively low number of items. However, even though TDR will result in a high burden for some contractors, it still pales in comparison to the current burdens imposed by the PRC and CSP disclosure requirements, which industry has already frequently acknowledged as burdensome.

Collecting and Managing the Data Effectively

Regarding the collection of data: there is a widespread misconception that the federal government already captures all the transactional data we need to make the best purchasing decision possible.  In reality, GSA only collects 1% of transactional data for orders placed through our ordering systems through GSA contract vehicles (e.g. GSA Advantage and eBuy), data is not currently collected through the Federal Procurement Data System (FPDS) or any other governmentwide acquisition system. Yes, the Office of Management and Budget (OMB) is working on its e-invoicing initiative to capture all government invoices electronically, and we are committed to working with OMB and partner agencies on the success of those initiatives.

And, GSA is ready to protect incoming data and use it effectively.  After all, that’s our business. GSA already collects and manages sets of reported data elements on contract vehicles including, but not limited to FSSI Office Supplies, Commercial Satellite Services and complex professional services under the One Acquisition Solution for Integrated Services (OASIS) vehicle, and we are committed to building on our existing successful best practices for storing and sharing data.

You might be wondering who will have access to this data and when.  First and foremost, transactional data will be available to and used by category managers to understand demand management and craft better buying strategies.  This is our main focus after sufficient data collection. In the future, we see foresee that GSA’s contracting officers (COs) will gain access to sets of data to evaluate and negotiate Schedule contracts in accordance with policies to ensure that MAS continues to focus on value, not low price, at the contract level.  Down the road, ordering activity COs will be able to consider the data analytics and pricing trends when placing orders.

GSA is currently reconciling public comments on the public disclosure of TDR information, and is committed to communicating the path forward to all stakeholders.

Join Us in This Pivotal Effort!

Now, federal and industry partners can join GSA as we continue to transform MAS, making it easier for agencies to meet their missions and buy smarter while reducing burdens on industry and supporting small enterprises seeking to do business with government.

We expect the added value of transactional data will make the Schedules program the vehicle of choice for the acquisition community.  And by driving contracting professionals to best-value contracts, we will ultimately reduce duplicative contract vehicles, lowering the transactional and administrative costs for both agencies and contractors.  Cutting those costs and making it easier to get on schedule, along with cutting back on redundant and inefficient procurement transactions, helps remove known barriers to entry into the federal marketplace, which is particularly important for the small business community.

The transactional data reporting requirement will be applied to any new GSA government-wide acquisition contract where transactional data is not already collected through other methods.  The rule requires monthly reporting on FSS contracts, Governmentwide Acquisition Contracts (GWACs), and Governmentwide Indefinite-Delivery, Indefinite-Quantity (IDIQ) contracts.

For FSS contracts, TDR is being implemented in phases, beginning with a pilot of specific Schedules and Special Item Numbers (SINs).  Please visit Interact for more detail about the pilot, the Vendor Support Center for recorded webinars and frequently asked questions, and the user-friendly FAS Sales Reporting site to report sales, view tutorials, and get online help.  Please also send any questions or feedback to our central TDR email box (tdrteam@gsa.gov), managed by a cross-functional team, to get your answers.

I know that change isn’t always easy, but as the stewards of more than $50 billion, GSA FAS must make the decisions necessary to obtain the best solutions for the American taxpayer – and putting TDR in action is one of those.  I look forward to remaining in close communication and cooperation with our industry partners, and to sharing our progress as we move forward with the Transactional Data Reporting rule.

 

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