To their credit, GSA leaders really want to work with you so that you understand the Schedules Transactional Data Rule (TDR). They’re sincere in this regard. As they dive in on a step-by-step response to industry concerns, though, the depth and breadth of the core issue is missed: The TDR, as written, is un-workable.
Taking a step back and looking at the TDR in a strategic spotlight would show that, no matter how well-intentioned the tactical response, the size and scope of the TDR are likely too ambitious for the agency and so burdensome for contractors as to drive some to the sidelines. It should be obvious that any program, procurement or otherwise, that generates over 60 questions and a nearly 20 page response from one industry group in just one letter probably has too many moving parts. That the letter came after the public comment period and issuance of the final rule only supports this conclusion. The response itself was so large, and deemed so important, it was picked up by the trade press.
More proof that TDR success faces a steep hill is GSA’s substantial investment in IT development for the system, training and education for industry, and training for government users. Someone needs to ask the questions: 1. How much is all of this going to cost? And 2. Who’s paying? Proceeding on the current path, no matter how well-intended, is very likely to result in significant costs and result in a system that can’t begin to meet stated expectations.
There is nothing so special about the current TDR approach that requires GSA to move ahead with it at any cost. GSA needs to see the questions, and significant internal hurdles, as proof that the TDR needs to be re-worked. There’s no harm in taking the time to do it well. Conversely, continuing with the creation of a Rube Goldberg-like contraption serves no one’s best interests.