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GSA Finally Confirms that Contractors Can Opt Out of Transactional Data Reporting

Client Alert | 1 min read | 08.18.17

On Thursday, the General Services Administration formally announced that starting with the new solicitation refresh (anticipated in October 2017), participation in the Transactional Data Reporting pilot will be voluntary. Significantly, GSA has also announced that contractors that were forced into TDR (for new contract awards, option exercises, or the addition of a TDR-covered SIN) will have a one-time opportunity to opt back out of TDR. While the long-term fate of the TDR approach to pricing (which replaces the requirement for Commercial Sales Practices disclosures and Basis of Award customer tracking) remains uncertain, this announcement suggests that these long-standing approaches will not be completely eliminated any time soon.


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Client Alert | 2 min read | 07.15.26

CMMC Phase II Suspension Requires Reconsideration of Such Requirements in Solicitations

As discussed in more detail here, the U.S. Department of War (DoW) recently issued a memorandum (Memo 26-P-1023, dated July 13, 2026) directing the immediate suspension of Cybersecurity Maturity Model Certification (CMMC) Phase II requirements. Significantly, the memo directs that “all pending and future CMMC implementation milestones across DoW solicitations and contracts are held in abeyance until further notice.” Moreover, the DoW issued a memorandum on implementing these requirements (available here), directing agencies to issue amendments removing CMMC Level 2 and 3 requirements from active solicitations “as soon as practicable.” Contractors should monitor the government’s compliance with this requirement and should be prepared, if needed, to file a bid protest to protect their rights....

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