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P-R-C You Later! GSA Previews Final Transition to Transactional Data Reporting for Schedule Contract Pricing

What You Need to Know

  • Key takeaway #1

    Beginning in late June, Transactional Data Reporting will become mandatory for nearly all GSA Schedule contracts.

  • Key takeaway #2

    At the same time, GSA’s longstanding Price Reductions Clause will be phased out, eliminating a significant source of historical liability.

Client Alert | 1 min read | 06.12.25

On June 9, 2025, the General Services Administration (GSA) Federal Acquisition Service (FAS) quietly announced that Transactional Data Reporting (TDR) would be exiting “pilot” status; under Refresh 27 to the Multiple Award Schedule (MAS), TDR will be mandatory for all eligible Special Item Numbers (SINs), effective beginning in the next sales reporting quarter after each contractor accepts the modification, with remaining SINs to be added in future refreshes.  

GSA first launched the TDR pilot in 2016 to study potential replacements for legacy disclosure and reporting obligations to ensure the pricing offered to GSA customers is fair and reasonable.  Those legacy obligations include the obligation to make Commercial Sales Practices (CSP) disclosures and to track commercial pricing and discounts to the negotiated Basis of Award customer under the Price Reductions Clause (PRC).  Under TDR, Schedule contractors submit quarterly monthly reports capturing 16 data elements for all sales made under the Schedule, obviating the disclosure and price-tracking requirements of GSA’s legacy CSP/PRC regime.

While the TDR pilot received positive feedback from industry, it met resistance from GSA’s Office of the Inspector General, creating doubt over the program’s future.  Nevertheless, FAS remained committed to the program, with Refresh 27 marking the culmination of efforts to make the Schedule program more accessible to industry.  

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IPR May Be Discretionarily Denied Because of “Settled Expectations” Where Petitioner Has Long Known of Challenged Patent

Acting USPTO Director Coke Morgan Stewart issued a Director Discretionary decision on June 6, 2025, in iRhythm Technologies Inc. v. Welch Allyn Inc., IPR2025-00363, -00374, -00376, -00377, and -00378 Paper 10 (PTAB June 6, 2025). This decision granted Patent Owner’s request for discretionary denials of institution in five related IPR challenges.  It follows several recent Director decisions that have all discretionarily denied petitions for reasons other than the substantive merits of the challenges. However, this decision is the first one that relies upon “[s]ettled expectations of the parties, such as the length of time the claims have been in force,” a new consideration that was first articulated in the USPTO’s “Interim Process for PTAB Workload Management” memorandum (“Interim Memo”) dated March 26, 2025....

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