Proposed GSAR Transactional Data Rule Summary and Comments
The proposed GSAR Transactional Data Rule, published on May 18, 2015, outlines the requirement for contractors to report transactional data from orders and prices paid by ordering activities under FSS and GSA non-FSS contracts. The rule aims to enhance GSA's ability to analyze pricing, validate fair pricing, and improve price comparison for customers. However, concerns have been raised about the potential negative impacts on suppliers, especially small businesses, and the need for better protection of confidential commercial information. Various resources and comments are available regarding this rule, including public comments and insights from industry experts.
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Presentation Transcript
Proposed GSAR Transactional Data Rule May 18, 2015
Transactional Data Proposed Rule Published March 4 Contractors to report transactional data from orders and prices paid by ordering activities FSS contract and GSA non-FSS contract orders (not VA) Report transactional data at the order and BPA level to GSA monthly 1. Contract or BPA Number 7. Unit Measure (each, hour, case, lot) 2. Order Number/Procurement Instrument Identifier (PIID) 3. Non Federal Entity, if applicable 8. Quantity of Item Sold 9. Universal Product Code (UPC), if applicable 10. Price Paid per Unit 11. Total Price 4. Description of Deliverable 5. Manufacturer Name 6. Manufacturer Part Number Slide 2
Transaction Data Survey Results Approx 70 member company responses Small, medium and large businesses 98% GSA Schedule contractors 42% have GWACs through GSA One quarter small business Initial Setup Burden Monthly Reporting Burden 68 hrs 70 1500 1192 1400 1300 60 38 hrs 1200 1100 50 GSA 1000 900 40 Small business 800 700 30 600 Other than Small 232 500 20 400 300 6 31 min 10 200 100 0 0 GSA Small business Other than Small Average hours Small Business Other than Small GSA Based on survey estimated total cost to implement transactional data is $814,700,534 30 times GSA s estimate of $24 million Slide 3
Transactional Data Reporting- Comments The proposed rule is not reasonably constructed to achieve GSA s stated objectives of: Improving GSA s ability to conduct meaningful price analysis and reduce price variability Validating fair and reasonable pricing Improve GSA customers ability to compare prices A system that continually drives down prices without regard to terms and conditions negatively impacts the supplier base, particularly small businesses, and ultimately the Federal customer The proposed rule does not adequately protect confidential commercial information Transactional data is already available from government and independent commercial sources Slide 4
Transactional Data Resources Coalition Public Comments Comment Summary GSA IG Public Comments Off the Shelf radio interview with former GSA IG Brian Miller Friday Flash Legal Corner by Jonathan Aronie Friday Flash Legal Corner by Brian Miller Slide 5
Section 508 NPRM Accessibility standards for ICT (Information and Communication Technology) published Feb 27 Applies to ICT developed, procured, or used by Federal agencies Conformance through VPAT Draft standards Ch 3 and 4 (Functional performance criteria and Hardware) Applicability of requirements to MFDs (e.g. 402 Closed Functionality) US Access Board interested in committee feedback Comments due May 28 Slide 6
Upcoming Events Webinar: Big MACs - Inside the Government's Super-sized Opportunities Bloomberg May 28 | 2:00- 3:00 p.m. Slide 7
