MAS contractors are required to report contract sales monthly under the Transactional Data Reporting (TDR) program and quarterly under the traditional Schedule program. Contract sales must be identified and separated from non-contract sales, both government and non-government. The following explain in detail how to determine what is and is not a reportable sale.
How to Determine if a Sale is Reportable
To determine whether if a sale is reportable, we need to differentiate a GSA sale from a not GSA sale.
What is a GSA sale?
If you are selling a contract item to an authorized user and there is no evidence of another contract vehicle in place, the order is considered a GSA sale. Any one or more of the following may indicate that a sale is a MAS sale:
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- Product or service is on your GSA contract, including items sold under the Order Level Materials (OLM) SIN
- GSA contract number is stated on the purchase order or task order
- Ordering information and terms like delivery are the same as your GSA contract
- Customer made contact with you through GSA Advantage or eBuy
- Customer pays with the governmentwide commercial purchase card
- Pricing is at or below the MAS price.
When a government order fits within the MAS contract parameters, the order should be considered a MAS sale unless the ordering agency indicates otherwise. When in doubt, ask the ordering organization if they are using your GSA contract for that order. If you have questions or need further clarification, please talk to your ACO.
What is not a GSA sale?
1. Open market items (i.e. non-contract items/services, other direct costs (ODCs), and travel) are NOT reportable sales. They can be included with contract orders, but must be clearly marked as open market, which are occasionally required to complete the full scope of an agency’s needs. As a contractor, you may be able to provide those items, even if they are not approved under your GSA contract, provided the ordering activity properly addresses them in the Request for Quote and any subsequent order, and you properly identify them in your quote. For example, an agency purchases a computer using a GSA contract; however, they also need a power strip for their new computer. You have power strips in stock, but not on your GSA contract. The power strip can be included in the order following the procedures in FAR 8.402(f), but is considered an open market item.
2. Work as a subcontractor (even if the end user is a government agency) is almost never a sale under your contract, and is therefore not reportable. There is one rare exception that allows work as a subcontractor to be reported under your GSA contract under very specific conditions in accordance with FAR 51.1 (Contractor Use of Government Supply Sources). In this scenario, a sale made to a prime contractor authorized to buy under FAR 51.1 is considered a reportable sale. Visit Acquisition.gov to learn more.
How to Report a Sale
All MAS sales are reported through the Federal Acquisition Service (FAS) Sales Reporting Portal (SRP). The FAS SRP is a safe, secure website for you to report both transactional and aggregate-level sales and payment data required by FAS procurement programs, including MAS, non-MAS programs such as the Governmentwide Acquisition Contracts (GWACs), and others. You can also report your sales through the VA Sales Portal, which allows firms with Federal Supply Schedule (FSS) contracts awarded by the VA to submit online sales reports and Industrial Funding Fee (IFF) payments electronically through the GSA/VA system, and the Electronic Subcontracting Reporting System (eSRS) a system that creates higher visibility for federal contracting officials who need to access and review subcontracting reports and introduces efficiency into the process of gathering information on federal subcontracting accomplishments.
Other Reporting Considerations
Reporting Sales for GSA MAS Contractor Team Arrangements (CTAs) Under a Contractor Team Arrangement (CTA), two or more GSA Schedule contractors work together in offering a total solution to meet the ordering activity’s needs. Authorized Dealers
Some contract holders elect to authorize a dealer(s) to sell products under their GSA contract on their behalf. This is a relationship that occurs when a contract holder authorizes a separate legal business entity to use their MAS contract. This relationship allows a contract holder to leverage the sales expertise of their dealer network to increase their GSA contract sales.
Important to note:
- An authorized dealer must be approved by the Procurement Contracting Officer (PCO) and incorporated into the contract.
- All contract terms and conditions that apply to the contract holder also apply to the dealer.
- An authorized dealer is not the same thing as a reseller, which holds their own MAS contract.
- A contractor’s sales tracking system must be able to recognize, track, and report eligible sales for all participating dealers.
- The dealer and contract holder need to carefully coordinate on invoicing and billing responsibilities.
If you are considering an authorized dealer relationship, discuss the requirements and relevant clauses with your PCO.