A New Dawn or New Nightmare: Will Transactional Data Reporting Reduce, or Merely Shift, GSA Schedule Contractors' Compliance Burden?
Client Alert | 1 min read | 06.23.16
Despite competing concerns expressed by both contractors and the IG, on June 23, 2016, GSA published a final rule proceeding with a pilot program imposing substantial monthly transactional data reporting obligations on contractors but relieving them from the burden of both commercial sales practices data submissions and the monitoring of commercial sales to tracking customers, as well as from the threat of price readjustments and possible FCA liability under the Price Reduction clause. The pilot program will initially apply to new contracts (and existing contracts where contractors elect to participate) under select GSA Schedules accounting for approximately 43 percent of GSA Schedule purchases, including Schedule 70 (Information Technology) and 00CORP (Professional Services), and continue for at least one year as GSA evaluates its ability effectively to collect and use transactional data and price analysis to assure better pricing for GSA Schedule customers.
Insights
Client Alert | 4 min read | 09.12.25
SBA’s OHA Further Defines Extraordinary Action in SDVOSB Appeal
On September 4, 2025, the Small Business Administration’s (SBA) Office of Hearings and Appeals (OHA) granted an appeal challenging SBA’s determination that a service-disabled veteran did not control an entity applying for Service-Disabled Veteran-Owned Small Business (SDVOSB) status based on a minority owner’s ability to block certain actions in the matter of VSBC Appeal of: Blue Skye Foods, LLC, SBA No. VSBC-442-A.
Client Alert | 6 min read | 09.11.25
U.S. Department of Commerce Partially Relaxes Export Controls on Syria
Client Alert | 9 min read | 09.11.25
Client Alert | 1 min read | 09.10.25