The GSA Office of the Inspector General (OIG) issued a new report last week again criticizing the Multiple Award Schedule’s Transactional Data Reporting (TDR) pilot.  A press release announcing the report stated, “…the agency has never used TDR pilot data in contract price negotiations”, but then went on to say, “…the collection of TDR data GSA has amassed is almost entirely unusable.”  It is unclear whether the OIG was more upset that the collected TDR data was unusable or whether Schedule’s program officials didn’t use it in making price reasonableness determinations.  What is clear is that the OIG either doesn’t know, or has forgotten, that the purpose of the TDR pilot was to move away from the use of contractor-supplied information to determine the price reasonableness of items offered through Schedule contracts.

The TDR program was designed to use market research as the primary means through which GSA CO’s would determine price reasonableness.  Then, after award, a company would report transaction level information on federal, not commercial, sales.  This information would, in turn,  be used by other federal agencies in determining whether the pricing they were offered on specific projects was competitive.  While this information may be of some use to GSA Schedule contracting officers in their market research work, the agency has already developed its own 4P pricing tool for to assist in making price reasonableness determinations.  It does not need to rely on “unusable” TDR information. The OIG report makes it seem as if a lack of usable TDR data leaves Schedule CO’s without a reliable means to review important pricing information.  This, manifestly, is not the case.

It’s tough to take the OIG report seriously because of these flaws.  The stridency with which the OIG has consistently opposed the TDR program may have clouded its ability to impartially evaluate it. The conflicting statements in the press release are just one example.  Selective evaluation of information may be another.  GSA Senior Procurement Executive Jeff Koses, for example, recently told a Coalition for Government Procurement Spring Conference crowd that the agency’s data show that TDR contracts actually result in better contract-level pricing than those negotiated via the traditional Schedule contracting route.

TDR has become a valuable way to enable innovative businesses to participate in the GSA Schedules program.  Federal customers benefit as a result.  The OIG may want to stop sputtering long enough to look at those benefits.