The General Services Administration’s Federal Acquisition Service, FAS, has made the Transactional Data Reporting, or TDR, rule mandatory across the entire multiple award schedule, a.k.a. MAS, program.
In an alert memorandum issued Friday, GSA’s Office of Inspector General said the rule implementation will happen “despite persistent data quality issues, lack of data usage for pricing decisions, lack of price competition and failure to support the OneGov Strategy.”
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What Is the Transactional Data Reporting Rule?
In June 2016, the GSA introduced TDR, which requires contractors to report transactional data, including with government customers, for products and services under their MAS contracts.
In exchange, contractors no longer have to submit their most favored customer and commercial pricing information.
According to GSA, TDR collects pricing data to better understand what products and services the government purchases.
By August 2016, GSA launched a three-year TDR pilot to improve the MAS program for federal customers and the American taxpayer. During the pilot, the agency said it would evaluate TDR based on a set of metrics, including changes in price and sale volume, small business participation, and purchasing strategies.
The pilot was extended through fiscal years 2019 and 2020.
TDR Pilot Findings
According to the inspector general, evaluation of the program in 2019 revealed that TDR data is not being used to improve purchasing decisions, but GSA still contended that the pilot is “on track to meet targets.” In a 2020 review, GSA also determined that the program meets or exceeds its targets, with plans to expand the pilot to the entire MAS program.
In 2023, the OIG audited the TFR pilot and found that the data collected was still not being used to negotiate pricing. Moreover, the inspector general revealed that the data amassed is “inaccurate, unreliable and unusable.”
Although GSA has since made improvements to the quality of TDR data it collected, about 73 percent of sales reported as of June 2, 2025 remain unusable.
The OIG warned in the memorandum that the expanded TDR rule implementation could place government agencies at risk of overpaying
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