GSA Transactional Data Reporting (TDR): What It Is, Role, Process
Transactional Data Reporting (TDR) replaced the cumbersome Commercial Sales Practices (CSP) and Price Reduction Clause (PRC) requirements for many GSA contractors.
Under TDR, you report actual sales data monthly through the FAS Sales Reporting Portal instead of maintaining complex tracking systems for your commercial pricing.
What is Transactional Data Reporting (TDR)?
GSA Transactional Data Reporting is a reporting method introduced in 2016 as part of GSA’s Federal Marketplace Strategy. This program collects standardized transaction-level data about purchases made through GSA contracts.
Here’s the basic idea: every month, you tell GSA exactly what you sold through your GSA contract: what product or service, how many units, what price, which agency bought it, where it went.
Why does GSA want all this information?
A few reasons:
- First, they’re trying to understand spending patterns across the federal government. If ten different agencies are all buying the same software, maybe they could negotiate better pricing as a group.
- Second, they want to see if contractors are offering competitive prices.
- Third, they’re moving away from the old Commercial Sales Practices model, which was complicated and didn’t give them useful data.
Launch Background
TDR started as a pilot program in 2016 with IT Schedule 70 contractors. The GSA had been working on modernizing their approach to pricing and sales practices for years. The old Commercial Sales Practices (CSP) format required contractors to disclose their commercial pricing structures and identify their “most favored customer.”
This system had problems. It was administrative-heavy for contractors, difficult to audit, and didn’t provide GSA with actionable market intelligence. So they tested TDR as an alternative.
The pilot was successful enough that GSA expanded it. Now TDR is mandatory for some contract categories and optional for others. The goal is to eventually move most GSA contractors to this model.
Benefits of a GSA TDR
TDR offers several advantages for GSA contract holders:
- No more Price Reduction Clause headaches. This is huge. Under the old system, if you gave a better discount to a commercial customer than what you offered GSA, you might have to reduce your GSA prices. Tracking this was a nightmare. With TDR, that requirement goes away entirely.
- Simpler contract modifications. Want to add new products or adjust pricing? Without TDR, you need to submit updated Commercial Sales Practices information, which can take months to process. With TDR, the process is much faster because you’re not tied to commercial pricing disclosures.
- More pricing flexibility. Since you’re not locked into commercial pricing relationships, you can respond to market conditions more easily. If you want to offer a special promotion to a federal agency, you don’t have to worry about triggering price reduction obligations.
- Better market intelligence. Contractors who participate in TDR get access to GSA Advantage! sales data and other market information. You can see what’s selling, identify trends, and adjust your strategy accordingly.
- Reduced audit risk. Commercial Sales Practices audits could be brutal. Auditors would dig through your commercial sales records looking for discrepancies. TDR audits focus on whether you reported your federal sales accurately, which is much more straightforward.
The downside?
You’ve got to report every single month, even if you had zero sales. And you need systems in place to capture all the required data elements. But for most contractors, the trade-off is worth it.
Mandatory vs. Optional TDR Participation
Not all GSA contractors must participate in TDR. Currently, the program operates under both mandatory and optional participation models:
- Mandatory TDR categories: Certain Multiple Award Schedule (MAS) categories require TDR. If your contract was awarded or substantially modified after certain dates in categories like IT, professional services, or facilities maintenance, you’re probably required to participate.
- Optional TDR categories: If you hold an older contract in a category where TDR isn’t mandatory yet, you can volunteer to adopt it. You’d need to modify your contract to add the TDR clause and remove the Commercial Sales Practices/Price Reduction Clause provisions.
- Pilot participants: Some contractors joined the original TDR pilot programs. They agreed to test the system in exchange for eliminating their Price Reduction Clause obligations.
To know your status, look at your contract. Section I-FSS-969 is the TDR clause. If it’s in your contract, you’re required to report. If it’s not there, check with your GSA Contracting Officer about whether TDR is available for your category.
Implications of opting in or out
When you choose TDR, you’re trading one set of requirements for another. Here’s what that means:
With TDR
- You start monthly transaction reporting
- Your Price Reduction Clause disappears
- You no longer maintain Commercial Sales Practices disclosures
- Contract modifications become simpler
- You get more pricing flexibility
Without TDR
- You continue quarterly sales reporting only
- You must maintain Price Reduction Clause compliance
- You need to submit CSP information with modifications
- You’re tied to your basis of award pricing relationships
- You face potential price reduction obligations
Consider your sales volume. If you process hundreds of transactions monthly, you need good systems to aggregate TDR data. If you only do a few large contracts per year, manual reporting might work fine.
Also consider your commercial pricing structure. If you offer lots of different discounts to various commercial customers, the Price Reduction Clause is complicated to manage. TDR eliminates that headache. But if you have simple, consistent commercial pricing, the Price Reduction Clause might not be that burdensome.
TDR vs. Traditional Reporting Requirements
| Aspect | TDR | Traditional (CSP/PRC) |
|---|---|---|
| Reporting Frequency | Monthly | Quarterly, sales totals only |
| Price Reduction Clause | Eliminated | Required |
| Commercial Sales Practices | Eliminated | Required |
| Basis of Award | Not applicable | Must maintain pricing relationships |
| Price Adjustments | Streamlined process | More documentation required |
| Administrative Burden | Moderate | Higher |
| Level of Detail Required | Transaction-level (every line item) | Summary totals by contract |
| IFF Calculation | Separate quarterly report still required | Based on quarterly sales report |
Transactional Data Reporting Requirements
Now let’s get into the specifics of what you actually need to report. GSA has defined required data elements and optional elements. You must include all required elements for every transaction. Optional elements are nice to have but not mandatory.
Required Data Elements:
| Required Data | Description |
|---|---|
| Contract number | Your GSA contract identifier |
| Task/Delivery Order Number or PIID | Specific order identifier |
| Non-Federal Entity | If applicable to transaction |
| Special Item Number (SIN) | Contract category code |
| Description of Deliverable | What was provided |
| Manufacturer Name | Who made the product |
| Manufacturer Part Number | Product identifier |
| Unit Measure | How quantity is measured |
| Quantity of Item Sold | Amount provided |
| Universal Product Code (UPC) | If applicable |
| Price Paid per Unit | Cost per item or service unit |
| Total Price | Complete transaction amount |
| Order Date | When order was placed |
| Ship Date | When order was fulfilled |
| ZIP Code of Destination | Where order was delivered |
Optional Data Elements:
| Optional Data | Description |
|---|---|
| Federal Customer | Specific agency information |
| Invoice Number | Billing reference |
| Invoice Paid Date | When payment was received |
Reporting frequency: You must submit reports monthly. The deadline is 30 calendar days after the month ends. So for January sales, your report is due by March 2nd (30 days after January 31st).
Zero sales months: You still report even if you had no sales. You submit a report indicating zero transactions for the month.
Where to report: You submit TDR through the FAS Sales Reporting Portal. You’ll need login credentials, which your company’s GSA point of contact should have.
Data format: The portal accepts manual entry for small volumes or file uploads (CSV, Excel) for larger datasets. Most contractors with significant sales volume automate the data export from their accounting systems.
Need Help? Road Map Consulting Services
Managing GSA transactional data reporting can get complicated fast. You need systems to capture all the required data, processes to ensure accuracy, and discipline to meet monthly deadlines.
Road Map Consulting specializes in helping federal contractors navigate TDR compliance:
