Article

A new era of transparency

CSP’s shadow over TDR

Aug. 21, 2025 · Authored by Leo Alvarez, Jeff K. Clayton

On June 9, 2025, the General Services Administration (GSA) announced one of the most consequential changes to the Federal Supply Schedule (FSS) program since its inception — it would begin expanding its Transactional Data Reporting (TDR) requirement across the entire FSS program. Starting with Solicitation Refresh 27, TDR will become mandatory for all product Special Item Numbers (SINs) and cloud service SIN 518210C, eventually extending to all remaining SINs.

Translation? The Commercial Sales Practices (CSP) disclosure and Price Reductions Clause (PRC) requirements will be eliminated (or, in the case of the PRC, significantly altered), relieving contractors of some of the most burdensome and risky aspects of GSA Schedule contracting. PRC liability, long viewed as a significant compliance risk due to its complexity and potential for costly penalties — will effectively disappear. But while this shift may appear to simplify the landscape for contractors, it also ushers in a new era of uncertainty.

TDR, while less burdensome in some respects, brings its own set of challenges: increased data transparency, heightened scrutiny of pricing consistency across federal agencies and potential questions around value and fairness — particularly if notable pricing differences emerge between agencies or contract vehicles. As the GSA shifts from historical pricing disclosures to real-time federal sales reporting, contractors must prepare for a fundamentally different risk environment — one that may be less predictable and potentially more demanding in terms of data integrity, pricing strategy and audit readiness.

The FSS pricing paradigm: A high-level primer

Since its inception, the FSS contracting model has been predicated on the principle that items offered under Schedule contracts should meet the definition of commercial items as outlined in Federal Acquisition Regulation (FAR) 2.101[1]. This notion of commerciality implies that the basic principles of supply and demand in the commercial marketplace will result in prices that are inherently fair and reasonable assuming adequate competition exists.

However, vendors are not awarded FSS contracts through direct competition with one another. Rather, the GSA evaluates each offer independently by comparing the proposed pricing and terms to those extended to the vendor’s commercial customers. This evaluation is meant to account for differences in terms and conditions that may influence commercial pricing and discounting practices, enabling the GSA to establish price negotiation objectives for the government.

Leo Alvarez

Principal

Jeff K. Clayton

Principal

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Date	Report	Summary
July 25, 2018	Audit of Transactional Data Reporting Pilot Evaluation Plan and Metrics (Report Number A140143/ Q/T/P18004)	Report finds that the GSA failed to establish defined performance targets tied to clear pilot performance objectives, and that TDR data has not been made available to allow for an evaluation against the metrics established by the GSA.
June 24, 2021	GSA’s Transactional Data Reporting Pilot Is Not Used to Affect Pricing Decisions (Report Number A140143/Q/6/P21002)	Recommended the GSA take immediate action to mitigate the risks associated with the TDR pilot and that the GSA develop and implement an exit strategy for the TDR pilot and transition participating contractors out of the TDR pilot.
Sept. 30, 2022	FAS Cannot Provide Assurance That MAS Contract Pricing Results in Orders Achieving the Lowest Overall Cost Alternative (Report Number A200975/Q/3/P22002)	The GSA OIG has consistently identified concerns regarding all aspects of the TDR pilot and recommended that the FAS commissioner cancel the TDR pilot.
May 1, 2023	GSA’s Fiscal Year 2020 Transactional Data Reporting Pilot Evaluation Provides an Inaccurate Assessment of the Program (Report Number A210081/Q/3/P23001)	Recommended the GSA cease the further expansion of TDR until the problems are corrected or the pilot is terminated; Includes six steps to follow to assess and confirm data accuracy, improve accessibility and utilization. If steps aren’t followed — the GSA should execute exit strategy.

	Mandatory TDR w/Refresh 27		All other SINs		Total SINs
Large category	SIN Count	% of Total	SIN Count	% of Total	SIN Count	% of Total
Industrial products and services	41	23%	0	0%	41	14%
Furniture and furnishings	30	17%	3	3%	33	11%
Security and protection	21	12%	6	5%	27	9%
Facilities	20	11%	4	4%	24	8%
Office management	18	10%	17	15%	35	12%
Scientific management and solutions	12	7%	3	3%	15	5%
Transport and logistic services	12	7%	11	10%	23	8%
Information technology	9	5%	11	10%	20	7%
Professional services	8	5%	34	30%	42	14%
Miscellaneous	6	3%	5	4%	11	4%
Human capital	0	0%	14	12%	14	5%
Travel	0	0%	6	5%	6	2%
Total	177	100%	114	100%	291	100%

A new era of transparency

CSP’s shadow over TDR

The FSS pricing paradigm: A high-level primer

Leo Alvarez

Jeff K. Clayton

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