On June 9, 2025, the General Services Administration announced the mandatory expansion of Transactional Data Reporting (TDR) across GSA’s Multiple Award Schedule (MAS) program. The mandatory expansion will begin at the end of June 2025, as a part of MAS Refresh 27, with 62 product special item numbers (SINs) not currently covered by TDR as well as the cloud services SIN. GSA will extend TDR as a mandatory requirement to all SINs beginning in fiscal year 2026. This is a momentous occasion, that, through collaboration, could benefit government and industry.
The benefits of TDR to the government are clear. TDR provides GSA with market intelligence about the pricing for the specific goods and services purchased under a MAS transaction, intelligence that is currently unavailable. TDR will enhance MAS price competition and result in better value solutions for the government and taxpayer. TDR will reduce overhead and supply chain costs, and aid in supply chain risk management. TDR will also provide other agencies with valuable price data that can be used governmentwide.
TDR benefits government and industry as well by reducing contract administration and compliance costs through the elimination of the Price Reduction Clause (PRC). The PRC dates back to the 1980s when the MAS program was 1) mandatory, 2) there were a limited number of MAS contractors and associated products, and 3) competition at the task order level was not required by statute. Under these conditions, the MAS was a limited tool used to acquire commodities based on price alone. The MAS has changed significantly since the 1980s. Services now outpace product purchasing and customer agencies use the MAS to purchase best value solutions such as cutting-edge information technology and cloud. The PRC is extremely burdensome and requires firms to identify their best commercial pricing for products and/or services sold at comparable terms and conditions, and then, for the life of the contract, constantly monitor their commercial operations to make sure that the firm never offers a commercial client a better price than the price offered to the government, at the risk of potential treble damages under the False Claims Act. Price protections such as PRC might make sense in the context of a sole source or requirements contract, but do not make sense in the highly competitive MAS market, where contractors receive a $2,500 guarantee and the opportunity to compete for orders with dozens, hundreds, or even thousands of other contractors. Some of the largest MAS contractors will tell you that because of the risks associated with PRC, the costs associated with PRC compliance far exceed the costs associated with TDR reporting. The costs of PRC compliance are even more debilitating to small businesses. TDR will make the MAS more effective and efficient for government and industry, both at the contract formation and transactional level, but only if the extra TDR burden is offset by elimination of the PRC burden.
While the transition away from PRC is highly valued and applauded by industry, it is important that GSA works with industry to implement the transition in an efficient and effective manner. There are industries, such as furniture and information technology, where the items are highly configurable and can result in thousands if not millions of possible permutations. For example, buyers of furniture have numerous options, including but not limited to the legs, handles, fabric, finish, orientation and other customizable options. Laptops are customizable based on memory, software, warranty, battery power, storage, audio, processor, etc. We respectfully request that GSA work with firms in these highly configurable industries to craft TDR reporting requirements for these industries that provide GSA with meaningful data, while not overburdening these industries with reporting requirements that will drive up costs for agency customers, costs that will ultimately be borne by the taxpayer. A worst-case scenario would be reporting requirements that are so onerous that firms in highly configurable industries leave the federal market altogether.
Moreover, under the MAS program, pricing and value are driven by competition at the order level for firm requirements and/or volume commitments from the government. In contrast, as noted, the contract level pricing is based on the overarching contract terms, namely, the $2,500 minimum guarantee and the corresponding opportunity to compete for future work (competition which requires investment in bid and proposal costs by MAS contractors). As such, it would be unreasonable to use order level pricing to negotiate contract level pricing. There are no volume commitments at the contract level. As GSA moves forward with this transformational initiative, members of the Coalition for Common Sense in Government Procurement stand ready to work with all stakeholders to streamline acquisition through TDR. We also look forward to the elimination of a costly regulatory regime (for government and industry) with the removal of the PRC.
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