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News Flash: GSA Issues Final Version of Transactional Data Reporting Rule, Calling for Phased Elimination of Both PRC and CSP

June 23, 2016

The General Services Administration (GSA) today issued a final version of its long-awaited and highly controversial Transactional Data Reporting rule, which will phase out both the Commercial Sales Practices (CSP) disclosures and Price Reductions Clause (PRC) monitoring requirements for participating vendors.

The new rule is part of GSA’s broader “Category Management” initiative, and is designed to provide Government purchasers with greater visibility into the prices charged to government customers, including quantity, unit price, and total price. GSA expects the reporting requirements will drive down prices because GSA and its agency customers will be able to use the “market intelligence” gleaned from reported data to make “smarter buying decisions.” 

In response to public comments, the final Transactional Data Reporting rule includes significant changes from the version originally published in March 2015, most notably calling for the phased elimination of both the CSP disclosure requirements and the need for PRC monitoring, as opposed to eliminating just the PRC as called for in the proposed rule.

Wiley Rein will be writing an Alert with more detailed analysis of the final rule and its potential implications for FSS Contractors in the near future. For questions regarding the final rule, or regarding FSS Contracts generally, please contact one of the attorneys listed on this alert.