According to the Federal Acquisition Service (FAS) Commissioner, Tom Sharpe, the General Services Administration (GSA) remains committed to a smooth transition in implementing the final rule governing transactional data reporting, released on June 23, 2016. As we previously reported, the final rule significantly changes reporting requirements for the Federal Supply Schedules (FSS) program – requiring vendors to electronically submit monthly reports providing 11 transactional data elements, and in turn, eliminate Commercial Sales Practices (CSP) disclosures and the Price Reduction Clause (PRC).

Last week, GSA published a blog reiterating the goals of the final rule on data reporting, as well as GSA’s continued commitment to efficient federal procurement. GSA’s post reminds contractors that the rule was adopted to address concerns over the burdensome requirements under CSP disclosures and the PRC. FAS Commissioner Sharpe assures the public that the final rule is beneficial to contractors, tax payers and federal agencies alike. Despite criticisms that the GSA underestimated the burden of switching to the new reporting system, Sharpe argues that even those contractors that will face a higher burden will be saving costs when compared to the CSP and PRC system. According to Sharpe, the pilot program alone has a net burden reduction of $29 million.

In his post, Sharpe also lays out the government’s broader goals in implementing the new reporting system. According to Sharpe, the rule is part of the government’s overall move toward category management and streamlining business in the public sector. In addition to lowering administrative burden, the final rule is an effort to eliminate contract duplication and to increase contracting opportunities under the Multiple Award Schedules (MAS) program. GSA projects that the final rule will be particularly beneficial to small businesses as it eliminates a barrier to entry and saves costs even prior to an award under a GSA schedule.

As our July update indicated, as part of the transition to the new reporting guidelines, the GSA requested comments on releasing the data collected to the public. Sharpe’s blog indicates that the GSA is still in the process of reviewing the suggestions they received from the public. In the meantime, GSA remains committed to protecting incoming data and conducting effective analysis. According to Sharpe, the data collected will first be made available to category managers that will analyze the information and develop better buying strategies for the government. In the future, the data can also be accessed by contracting officers to help in their efforts to evaluate and negotiate schedule contracts. The GSA hopes that the collected data will emphasize procurement based on best value rather than lowest price.

While the comment period for input on the public release of data collected has closed, the GSA encourages continued dialogue between the public and the agency. To ensure transparency and successful implementation, GSA is accepting questions and feedback through its central email box for the final rule ( Finally, the GSA promises to work with other agencies colleting vendor and purchasing information – including the Office of Management and Budget – to ensure that all data is collected and managed effectively.

We would like to thank Lidiya Kurin, a Bass, Berry & Sims law clerk based in our Washington, D.C. office, for her assistance in drafting this alert.