Weighing The Pros And Cons Of GSA Transactional Data Rule

Law360, New York (July 27, 2016, 2:56 PM EDT) -- You no doubt have heard by now about the U.S. General Services Administration's June 23 effort to "embrace modern technology while moving away from outmoded practices" — specifically, its implementation of the new transactional data reporting rule ("TDR rule") and its concurrent elimination of the price reductions clause ("PRC") and the commercial sales practices format ("CSPF"). See 81 Fed. Reg. 41104 (June 23, 2016). The new rule covers certain GSA Multiple Award Schedules as well as the agency's governmentwide acquisition contract and indefinite delivery/indefinite quantity contracts. As it represents the most significant change to the GSA MAS program since 1994 (when the GSA removed federal sales as a PRC trigger), the new rule has the potential to change significantly the way Schedule contractors (and others) do business; hence, my willingness to interrupt your otherwise enjoyable day with a treatise on GSA Schedule contracting....

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