Mar 18, 2015

“Oh, oh, oh

For the longest time

Oh, oh, oh

For the longest time”

Everyone has by now been inundated with articles and blogs on the proposed GSA rule requiring transactional data reporting.   Here is the quick read summary. GSA has a draft rule that would require vendors to report transactional data from orders and prices paid by ordering activities. This includes orders placed both against GSA Schedules and GSA’s non-schedule contracts such as GWACS and IDIQ contracts. The new clause would be paired with changes to the price reductions clause.

But what I didn’t know was that this draft rule had its genesis in the 2010 Multiple Award Schedule Advisory Panel recommendations. I learned this fact, thanks to Alan Chovtkin, Executive Vice President and Counsel at PSC. (Read PSC ‘s GSA Schedule Reform)

It is clear that change with the price reductions clause takes the longest time.   And since the reporting burden will be on contractors for monthly reporting it will also take the longest time because the rule will require reporting on eleven separate items. The draft rule is vague on how these reports would be filed other than a mention of GSA implementing an electronic system to collect the data. Those of you who have used the System for Award Management (SAM) will not be amused by GSA’s estimate of a one time initial set up burden for contractors of 6 hours and a monthly reporting burden estimated to be 31 minutes per month. Yes, it will be the longest time.

I encourage everyone to either post comments or attend the public meeting on April 17, 2015.   Written comments must be submitted before May 4, 2015.

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