By: s.m.amend | March 20, 2017

General Services Administration’s new Transactional Data Reporting (TDR) rule states that contractors must electronically report prices paid by the federal government for goods and services purchased through GSA acquisition vehicles. (Interact.gsa.gov). GSA intends to gain market intelligence about pricing, while improving efficiency and reducing requirements that many contractors found challenging.

TDR is significant not only because of the new reporting requirement, but also because it eliminates the long-standing task for contractors to track their Basis of Award customer’s price reductions, as the new Price Reductions clause does not include a BOA tracking stipulation.

Using a phased-in approach affecting select schedules and SINs, the ...

By: s.m.amend | October 03, 2016

Did you know that if you purchase or subcontract anything under your government contract that you are subject to almost all the same rules as the federal government follows?  By using your contract money to procure goods or services to support that contract, you are using taxpayer money that is subject to many rules and possibly audit. As a government prime contractor, you must know how to properly spend your prime contract money and also reduce your corporate risk.  An audit is something many government contractors will face, if you are caught not spending the money correctly, you could be subject to repaying the government or fines.

The Federal Acquisition Regulation (FAR) is not entirely written for contractors, however contractors that i...

By: s.m.amend | September 07, 2016

New FAR Subpart Requires Government Contractors to Safeguard Information Systems

Over the summer, a new subpart was added to the Federal Acquisition Regulation (FAR) that adds to contractor compliance requirements.  Effective June 15, 2016, GSA, NASA, and the DoD issued a final rule to add new clause and Subpart 4.19 for the protection of contractor information systems that “process, store or transmit Federal contract information.”--federalregister.gov

The clause applies to any contractor system with federal information; the goal of the language is to be “reflective of actions a prudent business person would employ” and is one of several regulatory measures coordinated with other government agencies to guard information systems.  For exampl...

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By: s.m.amend | August 29, 2016


On June 13, 2016, the General Services Administration issued the final Transactional Data Reporting (TDR) rule.  TDR requirements state that contractors must electronically report costs paid by the federal government for goods and services procured from GSA contract vehicles.  The goals of TDR are to reduce tracking requirements, save taxpayer dollars, and gain valuable market intelligence. 

The TDR pilot program began August 2016.  Requirements will be phased in, affecting select schedules over the next few months.  Gsa.gov’s blog states that TDR will not become permanent before the pilot program is evaluated for at least one year. 

Going forward, schedule holders are no longer responsible for tracking price reductions to their Basis of...

By: s.m.amend | August 25, 2016

The General Services Administration issued the final version of its much-discussed Transactional Data Reporting (TDR) rule; on June 23, 2016, it was published in the Federal Register and will be phased in through a pilot program affecting select schedule and special item numbers.  The GSA’s goal is to remove contractors’ difficult reporting requirements and save millions of taxpayer dollars.   

The TDR rule also marks the elimination of the Commercial Sales Practices disclosure and Price Reductions Clause. 

On the CSP-1 document, a GSA schedule holder was required to disclose each category of customer to whom they offered similar products/services and the discounts each received. 

One of the most challenging aspects of PRC compliance req...

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