GSA should stand by the TDR program

The General Services Administration’s Transactional Data Reporting (TDR) system is a good option through which companies can obtain GSA Schedule contracts. Despite recommendations by the GSA Office of Inspector General (IG), GSA should retain and expand the use of the TDR path for Schedule contracts.

Full disclosure: I was not a fan of the TDR program when it was originally introduced. My concern was that companies would be pressured into providing commercial sales information, despite TDR’s stated intent of not relying upon it, without any parameters over what was considered “enough” information. While those are still valid concerns that any company considering TDR should evaluate, the option has shown itself to be a viable alternative to the traditional Schedule offer process.

The recent IG report stated that TDR “has not resulted in a viable pricing methodology that ensures compliance with Competition in Contracting Act requirements for orders to result in the lowest overall cost alternative to meet the government’s needs.” Yet, one of the main reasons the IG makes this claim is because GSA contracting officers (COs) did not have “access” to market research data or did not know how to use it. The use of market research is a long-established principle through which contracting officers can establish price reasonableness on a commercial item contract. If GSA’s Schedule COs don’t know how to use market research in a TDR situation, it’s not because that method is faulty. Rather, it suggests that GSA needs to improve training for COs.

Say, for example, that, as is the case with TDR, the IG had come out with a report six years after the Model T had been released. Most people wouldn’t know how to drive the Model T, even if they had seen one. Based on the IG’s logic, however, Henry Ford should have closed up his factory and gone back to the livery stable. It should not be surprising that acquisition professionals need more time to understand how to use TDR.

Further, one part of the IG report criticizes COs for using pricing tools in lieu of obtaining more contractor data. Another, however, criticizes COs for using their research skills when overriding a pricing tool. If this seems confusing to you, imagine how it looks to a GSA CO.

Indeed, the GSA IG has had little, if anything, positive to say about the Multiple Award Schedule program in the over 32 years I have worked in this field.  Prices have always been considered “too high,” despite market forces that drive prices down at the task order level and regulatory language that requires buyers to seek a price reduction when making a purchase of any dollar amount via a Schedule contract. GSA Federal Acquisition Service (FAS) leadership, which pushed back on several IG recommendations, is right to be skeptical about pleadings from an organization that has seldom had anything but criticism for the government’s largest commercial item acquisition program.

TDR has, in fact, allowed hundreds of new businesses to participate in the Schedules program. Most of these companies are small businesses, a key demographic that GSA wants to attract. Those companies not only increase competition at the task order level, lowering prices that federal customers actually pay, but resulted in new technologies and solutions being more readily available to federal buyers.

The Schedules program is a better tool for both small contractors and government agencies because of TDR. That’s not something to be dismissed lightly.

Larry Allen is the president of Allen Federal Business Partners and has been involved in federal procurement for more than three decades.

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