By Linda Rodden
Compliance Consultant, Point Compliance Group
The Transactional Data Reporting (TDR) Pilot is underway at GSA. TDR will be implemented in a phased pilot approach beginning August 2016 and extending through the first quarter of FY2017. The TDR Pilot applies to all Schedule Contractors who have the following 8 Schedules and SINs:
As explained in the June 23, 2016 Federal Register, reporting is not limited to just the specific SINS identified. If a Schedule Contractor also has other SINs awarded under these contracts, the TDR pilot applies to those SINs as well. The pilot will be implemented via a MAS Mod. Schedule Contractors will have approximately 90 days to accept the Mod. It is important to note that the pilot is optional – Schedule Contractors can opt not to participate. However, TDR will be mandatory for new offers.
The reporting requirements for the TDR pilot become effective on the first day of the business quarter following acceptance of the modification, i.e., April 1, July 1, October 1, or January 1, as applicable based on the acceptance date. The TDR Pilot is scheduled to be in effect for 3 years. If the pilot is accepted, the contract will be modified to delete these requirements: the current price reduction clause with Basis of Award tracking and all CSP requirements.
Transactional reports will be required monthly and the IFF fee will still be paid quarterly. The report is due 30 days after then end of the month and the IFF fee is still due 30 days after the end of the quarter. The new report of GSA sales will have the following fields:
(i) Contract or Blanket Purchase Agreement (BPA) Number
(ii) Delivery/Task Order Number/ Procurement Instrument Identifier (PIID)
(iii) Non Federal Entity. (i.e. State or Local Government entity or Federal Prime Contractor)
(iv) Description of Deliverable
(v) Manufacturer Name
(vi) Manufacturer Part Number
(vii) Unit Measure (each, hour, case, lot)
(viii) Quantity of Item Sol
(ix) Universal Product Code, if there is one
(x) Price Paid per Unit
(xi) Total Pric
Contractors will have the following options to submit their sales:
1. Form entry - where you fill out a form in your web browser
2. File upload - where you upload an excel or .csv template populated with your sales data
3. Electronic Data Interchange / EDI
4. Web Services / API
GSA has not provided details on these methods; however, if your company’s reporting system is designed so that it can accommodate the file upload method, the other methods will most likely be manageable.
Contractors will be required to utilize a “digital certificate” to gain access to the TDR system which is the same as the eoffer - emod system requirement. This is a change from the current 72A reporting system. There is no digital certificate requirement for accessing the 72A reporting system. Contractors will have the opportunity to explore a test environment to confirm their digital certificate is in order and select the best reporting format. Training will be offered.
The key is to be prepared for the transition to the TDR requirements. Preparation for the pilot should include your company exploring/testing/maintaining the following:
1. Determine if the data required can be extracted from the invoice system.
2. Determine if the invoice system tracks to the quoting system. GSA has stated in their FAQs that they expect the fields to match the quote. This could be an issue to raise for the pilot if invoices and quotes can vary.
3. Determine accuracy of data for the report. This report replaces the IFF 72A report and the same accuracy is required but with more data fields. It is recommended to implement several test runs before agreeing to the pilot.
4. If there are channel partners with invoicing and payment authorization, agreements will need to be modified to capture the data promptly and correctly from them. If all channel partners do not agree then the pilot will not be possible. It will be more work for them without the comparable benefit of no CSP/BOA. Consider compensation and begin a process to be able to comply within 3 years.
5. Sign up for GSA training when announced.
6. Continue to monitor BOA and CSP until the pilot is launched and the contract has been modified.
While all of these preparation activities are important, #6 is critical to maintain from a compliance perspective until after receipt of the executed MAS MOD.
It is important to consider the specific factors when deciding if the TDR Pilot is right for your organization. First, the take into account the benefits. Benefits of the TDR Pilot include:
1. Deletion of the CSP and BOA will reduce the liabilities inherent in these clauses.
2. The reporting site will be more flexible and manageable than the current 72A reporting site. There will be a single sign in for all reports and a simple $0 reporting process. And a big bonus - corrections will be easier.
3. The reporting site will keep a running fee total for schedule sales.
Additional considerations that impact the decision to participate in the TDR pilot include the following:
1. Liability for accuracy of the reports will replace the liability for accuracy of CSP and Price Reductions.
2. GSA will be making some of the data public. They have not yet determined what or how. This will be issued as a separate rule.
3. GSA expects that this process will result in lower prices and less variability as each agency will see the data and will compare the pricing to their own quote.
4. Quotes may require more backup if they are not matching the lowest ones out there.
It can be rough going at GSA when something new is implemented. Patience will be important as contractors and GSA personnel work to understand the new system. As always, Point Compliance Group is here to help smooth the transition. If you choose to participate, good luck and send us your thoughts on the process at firstname.lastname@example.org or leave us a message: http://pointcompliance.com/contact/.
Until next time,
Compliance Consultant, Point Compliance Grou