The Transactional Data Reporting (TDR) pilot is a good option for many would-be GSA Schedule contract holders.  The program makes it easier for companies to obtain – and comply with – a Schedule contract.  That does not, however, mean that there are no compliance requirements for TDR contractors.  Companies need to be aware that they are open to an audit or whistleblower action anytime they submit information to a government agency or make a representation about their compliance with various contracting rules.  Companies electing to take the TDR path do not have to submit Commercial Sales Practice (CSP) sheets or agree to a Basis of Award customer class as traditional Schedule contractors do.  They still, however, need to ensure that any information they provide to GSA that the agency then relies upon to make a price reasonableness determination and subsequent award accurate.  While CO’s are supposed to use non-contractor supplied information to determine price reasonableness when using TDR, anecdotal evidence suggests that companies are sometimes still asked for sales data.  CSP’s must be a full and accurate representation of a company’s commercial sales and discount practices for the proceeding 12-month period, but there are no guidelines for what is necessary for a TDR award.  It is essential, therefore, that any company in this situation make clear, in writing, the scope of information they are providing to GSA, what it represents, and what it does not represent.  Pricing also isn’t the only compliance issue for TDR contractors.  They must attest to their compliance with a host of government rules, including Trade Agreements Act compliance, veteran hiring reporting requirements, Section 889 mandates, and small business subcontracting plans if the company is a large business.  The TDR Schedules option is a good option that benefits both industry and government.  Contractors need to make sure, though, that, with few exceptions, their compliance efforts meet those of any other Schedule contractor.