Multiple Award Schedule (MAS) contractors not presently participating in transactional data reporting (TDR) will now have to do so and come into compliance with the TDR rule soon after their MAS contract's Special Item Numbers (SINs) have been added to the TDR program. In any event, all MAS contractors will have to be in compliance with the TDR rule by fiscal year (FY) 2026, as the U.S. General Services Administration (GSA) announced on June 9, 2025. The expansion begins with 62 new product and cloud services SINs when GSA issues its next mass modification by the end of June 2025.
Below is a brief history of GSA's TDR program and key takeaways from the announcement. MAS contractors must ensure they have the resources and systems capabilities necessary to capture line-item-level detail. This access will be critical to success after the pivot away from traditional Commercial Sales Practices (CSP) disclosures and Price Reductions Clause (PRC) basis-of-award monitoring and reporting requirements.
What Is GSA's TDR Rule?
The TDR rule currently requires participating MAS contractors to submit monthly reports of the prices paid for GSA MAS products and services sold, along with other transactional data, on a line-item basis.
Brief History of GSA's TDR Rule
- June 23, 2016. GSA implemented the voluntary TDR pilot program. The program was rolled out over a one-year period. At that time, it was limited to 63 MAS SINs out of 324 total and focused on office products and equipment, tools and hardware. The pilot identified 12 data fields for collection, and participation was optional for holders of the identified SINs. The TDR rule and pilot program specifically excluded the Federal Supply Schedule (FSS) contracts administered by the U.S. Department of Veterans Affairs (VA).
- April 2024. GSA issued a mass modification to participating MAS contractors to expand the number of data fields collected to 16.
- August 2024. GSA issued another mass modification to MAS contractors to expand TDR eligibility to an additional 67 SINs. The now 130 SINs eligible for TDR covered most nonconfigurable product offerings across office management, facilities, security and production, industrial and scientific products, information technology, and transportation and logistics equipment.
- 2024 Compliance Assessment Procedures. GSA developed compliance assessment procedures and new field controls in the sales reporting portal to improve the quality of the data being captured.
Implications for MAS Contractors
GSA's end of voluntary participation in TDR will eliminate CSP disclosures and PRC basis-of-award monitoring and reporting requirements once TDR is implemented for all MAS SINs. As a result, GSA's Office of Inspector General investigations into compliance with MAS contract terms and conditions also will be narrowed.
GSA's changes to MAS contracts likely will appeal to more commercial businesses that have the systems and capabilities to comply with the TDR rule's monthly reporting requirements. The effect may be more businesses pursuing MAS contracts as the government continues to align itself to commercial-friendly procurement practices.
As has been the case since the TDR pilot program was commenced in 2016, GSA did not apply its expansion of the TDR rule to the FSS contracts administered by the VA, which will continue to require CSP disclosures and PRC basis-of-award monitoring and reporting requirements.
