Tuesday Insight – July 26th, 2022: GSA FAS to Expand TDR Rule Despite Persistent Data Issues, OIG Says

Aug 8, 2022

The U.S. General Services Administration (GSA) Office of Inspector General (OIG) has issued an alert memorandum detailing that the Federal Acquisition Service (FAS) is planning to expand the Transactional Data Reporting (TDR) Rule to the entire Multiple Award Schedules (MAS) Program by November 2022.

FAS’ plan to do so comes despite ongoing issues with data quality and access issues placing agencies at risk of overpaying for products and services when utilizing FAS’ MAS contracts, the OIG said.

“FAS is planning to expand TDR to the entire MAS Program despite persistent issues with the quality of TDR data and contracting personnel’s lack of access to TDR data that is usable for pricing decisions,” the memorandum says. “In particular, FAS does not consistently verify the product and pricing information entered by contractors, which could result in the retention of inaccurate information in the TDR database.”

FAS contends that it is the contractor’s responsibility to enter accurate and reliable information. But according to the OIG, “FAS contracting personnel will rely on unverified information to make pricing decisions; therefore, it is incumbent on GSA to either ensure that the data is accurate and reliable or discontinue the pilot.”

When evaluating fiscal year (FY) 2022 TDR data, the OIG also found data from sales is unusable because it doesn’t align with the product part numbers on reporting contractors’ MAS contracts. According to the OIG, this is another factor in determining that FAS has not demonstrated that TDR is reliable and ready for expansion.

In addition, the OIG found that TDR data for professional services is “almost completely” unusable and never included in any GSA evaluations, while also determining that this data will be “extremely difficult to standardize and what contractors enter varies greatly.”

The memo closes with the OIG stating that despite the TDR pilot being in effect within the MAS program for five years, it has yet to accomplish its intended purpose.

“FAS’s collection of TDR data is not being used to make decisions that affect pricing,” the OIG wrote. “This is due to a myriad of issues, including that the TDR data is inaccurate and unreliable and FAS contracting personnel do not have access to data that can be used for pricing decisions.”

The OIG also described “recent discussions” in which FAS senior leadership “stated that TDR would not be expanded unless access and usability issues were corrected.”

“However, these issues have not yet been corrected and we doubt they can be corrected before November 2022,” the OIG said. “Moreover, FAS’s plan to conduct new training for FAS contracting personnel in July and August 2022 regarding their role in the TDR expansion indicates the expansion will not be delayed.”

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