When a government agency asks for comments on the same topic twice in one year it is time to sit up, take notice and act!  GSA did just that last week with the issuance of a second notice seeking contractor input on a host of Price Reductions Clause compliance issues and, this time, threw in questions about Commercial Sales Practice Sheet disclosures for good measure.  GSA asked for PRC comments in October of 2015, and again last April as part of their Transactional Data exercise.  There can be no clearer indication that the agency is seriously contemplating changes to the PRC for the first time in decades.  Similarly, the issuance of multiple notices indicates that the agency is likely struggling internally to find a balance between burdensome tracking requirements and, according to the IG community anyway, a Schedule feature that helps ensure price reasonableness.  It is absolutely essential that industry respond to the notice.  Among the questions the agency wants answered is whether a compliance system burden should be allocated over the full 20 year life of a contract or over a smaller period of time such as 5 years or 1 year.  Before responding, companies should keep in mind that GSA auditors and the Department of Justice today routinely go back well beyond five years of data collection as part of any False Claims Act case.  You can be sure that the IG community will weigh in with its thoughts.  Make sure yours are heard as well.  Comments MUST be turned in by May 11th.  See the notice here: