TRANSACTIONAL DATA REPORTING (TDR): NOW THAT THE RULE IS FINALLY HERE, WHAT SHOULD GSA SCHEDULE CONTRACTORS DO?

Troutman Pepper
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Pepper Hamilton LLP and BDO USA, LLP presented a complimentary “virtual round table” webinar. These are the PowerPoint slides from that webinar.

On June 23, GSA issued a long-anticipated final rule - commonly known as the Transactional Data Reporting Rule (TDR) - which will fundamentally change the pricing rules for GSA Schedule contracts. The TDR does away with the long-established pre-award commercial customer pricing disclosure (CSP-1) and post-award Price Reductions Clause (PRC) monitoring requirements, in favor of a newly-created monthly pricing report of government sales transactions under the contract.

Our roundtable members, each with substantial industry experience, discuss the “knowns” and “unknowns” of the TDR, as well as practical suggestions for what GSA Schedule contractors should do in response to the TDR. Topics include:

- when is the TDR effective?

- what does the TDR report require?

- TDR effect on other (non-Schedule) GSA contracts

- whether to elect voluntary coverage

- unique considerations for professional services

- what should contractors be doing now?

- forecast of gaps created by the TDR and possible problem areas for contractors.

Please see full publication below for more information.

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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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