GSA MAS Refresh 27: Mandatory TDR, End of PRC, and What Contractors Need to Know

The General Services Administration (GSA) is ushering in a new era for the Multiple Award Schedule (MAS) program with MAS Refresh 27, scheduled for release in June 2025. The most significant change: Transactional Data Reporting (TDR) will become mandatory for all product Special Item Numbers (SINs) and cloud SIN 518210C and will soon expand to cover all SINs across the MAS program. This shift phases out the long-standing Price Reductions Clause (PRC), streamlining compliance and providing the GSA with more robust market intelligence.

Key Impacts for Contractors

1. TDR Becomes Mandatory:

• With MAS Refresh 27, TDR will be required for all product SINs and cloud SIN 518210C, and GSA has announced plans to make TDR applicable to all SINs beginning in Government FY26.
• The effective date will coincide with the start of the next sales reporting quarter after the modification is executed.
• Contractors must report detailed transactional sales data (price, quantity, customer, etc.) monthly.

2. PRC Liability Ends with TDR:

• Once TDR is effective, PRC compliance will no longer be required, reducing the administrative burden and audit risk associated with tracking Basis of Award (BOA) customer pricing.

3. Increased Scrutiny on TDR Pricing:

• As TDR becomes the sole reporting mechanism, expect GSA to apply more scrutiny to reported transactional data and pricing practices when it comes time for option renewals or upon initial contract award.
• Now is the time for contractors to review their data collection, pricing, and disclosures to verify accuracy and compliance before TDR is in effect.

4. Proper Disclosures Remain Critical—At Award and Renewal:

• Even as TDR replaces the PRC, contractors must still set up pricing, commercial sales practices, and accurate disclosures at the outset of a contract and during each option renewal.
• Contractors should conduct similar analyses and reviews to keep pace with the GSA Schedule, and should also do so at every renewal year or option period to maintain ongoing compliance and proactively address any changes in pricing or business practices.

5. VA Programs Remain Unaffected:

• The Department of Veterans Affairs (VA) Federal Supply Schedule (FSS) is not impacted by these changes. The PRC remains in effect for VA FSS contracts, so contractors must continue to monitor and comply with PRC requirements for their VA Schedule contract.

Action Steps for Contractors

• Review and Clean Up Data: Assess whether sales and pricing data are accurate and ready for increased transparency and potential scrutiny under TDR.
• Update Internal Processes: Adapt compliance programs and training to focus on TDR reporting and eliminate PRC monitoring where applicable.
• Prepare for More Oversight: Proactively address any inconsistencies or errors in reported data, as GSA will be paying closer attention to TDR submissions.
• Monitor VA FSS Requirements: For those holding a VA FSS contract, continue to comply with PRC and stay alert for any future changes.