The Transactional Data Reporting (TDR) Rule requires vendors to electronically report the price that the federal government paid for an item or service purchased through GSA acquisition vehicles and other data elements. The rollout of TDR across all pilot schedules is now complete. If you accepted TDR willingly or unwillingly, it’s time to understand the reporting requirements.
When are the TDR Requirements Effective?
Upon acceptance of the TDR pilot bilateral mass modification, the requirement for providing a Commercial Sales Practice (CSP) disclosure to accompany modification requests will be eliminated. In addition, vendors will no longer be required to track price reductions granted to their Basis of Award (BOA) customer or category of customers. Price Reduction Clause liability for current contractors ends with acceptance of the TDR mass modification, which will be effective on the first day of the business quarter following acceptance of the modification.
In order to ease the transition from the current 72A reporting database to the TDR reporting module, the requirement for commencement of reporting will not begin on the date the modification is signed; rather, reporting will begin at the beginning of the next full business quarter as shown below:
|Modification Accepted||Requirements Effective|
|July 1 – September 30||October 1|
|October 1 – December 31||January 1|
|January 1 – March 31||April 1|
|April 1 – June 30||July 1|
If a current contractor accepts the modification during the last 15 days of a standard business quarter, reporting begins on the first day of the second business quarter following modification acceptance.
What Data Am I Required to Report?
The clause requires contractors to submit the following data elements:
- Contract Number
- Order Number or Procurement Instrument Identifier (PIID)
- Non Federal Entity, if applicable
- Description of Deliverable
- Manufacturer Name
- Manufacturer Part Number
- Unit of Measure (each, hour, case, lot, etc.)
- Quantity of Item Sold
- Universal Product Code (UPC), if applicable
- Price Paid per Unit
- Total Price Sold
Contractors should report Firm Fixed Price (FFP) orders as single line item representing the lump sum total for the order. For services time-and-materials (T&M) or labor hour orders, reporting should be done by labor categories and rates.
Manufacturer Name is not a mandatory field for service contractors in TDR, but Description of Deliverable is a mandatory field for both products and services. Service providers would place a brief description of the project or service offered in the Description of Deliverable field.
How Can I Complete the Reporting?
Contractors have multiple options to submit their sales data such as:
- Form entry – where you fill out a form in your web browser
- File upload – where you upload an excel or .csv template populated with your sales data
- Electronic Data Interchange / EDI
- Web Services / API
In summary, TDR data is reported monthly and there is a 30-day window to report after the end of the month. Your Industrial Funding Fee (IFF) must be paid quarterly. Contractors may, however, choose to remit IFF on a monthly basis when they report their sales if they prefer and must do so through the TDR system. For TDR Pilot contractors under Schedules 70 and the Professional Services Schedule, if TDR SINs are included on a contract alongside non-TDR SINs, the entire contract is subject to TDR terms and conditions, and CSP and PRC requirements are removed for the entire contract. Remember that participation in the TDR Pilot does not exempt the contractor from existing reporting requirements found elsewhere in the contract.
About the Author:
Julia Coon is GSA and VA Contract Consultant at Centre Law & Consulting. Julia works with the GSA/VA team in preparing new schedule proposals and post-award contract administration. She has experience in producing schedule renewal packages, various modification packages, small business subcontracting plans, and updates to GSA pricelists.