General Services Administration
Transactional Data Reporting;
OMB Control Number, 3090-0306
Justification – Part A Supporting Statement
Overview of Information Collection:
This is a request for approval of a revision to an existing information collection.
This information collection applies to General Services Administration’s (GSA) contracts subject
This information collection applies to General Services Administration’s (GSA) contracts subject to transactional data reporting (TDR) requirements. TDR requirements can apply to Federal Supply Schedule (FSS) contracts and non-FSS contracts. The basis for TDR is to collect transactional data, which encompasses the historical details of the products or services delivered by a contractor during the performance of task or delivery orders issued against a contractor’s contract.
The following are the General Services Administration Acquisition Regulation (GSAR) sections covered by this information collection:
515.506
538.273*
The following are the GSAR clauses1 covered by this information collection.
Non-FSS clauses:
552.216-75, Transactional Data Reporting
FSS clauses:
Alternate I of 552.238-80, Industrial Funding Fee and Sales Reporting*
Alternate I of 552.238-81, Price Reductions*
552.238-83, Examination of Records by GSA
552.238-85, Contractor’s Billing Responsibilities
552.238-120 Economic Price Adjustment—Federal Supply Schedule Contracts
*See CD-2025-13 for information on the impact to these GSAR sections/clauses as it relates to TDR and the FSS program.
The following are changes of importance that have occurred since the last extension approval:
The following GSAR clause is removed from this information collection.
552.216-70, Economic Price Adjustment—FSS Multiple Award Schedule Contracts2, has been removed from this information collection. The reason is because the GSAR clause, including its alternate, was removed from the GSAR via GSAR Case 2020-G510 Final Rule, effective September 4, 2024 (see 89 FR 63325).
The following GSAR clause is added to this information collection.
552.238-120, Economic Price Adjustment—Federal Supply Schedule Contracts has been added to this information collection. The reason is because the clause was added to the GSAR via GSAR Case 2020-G510 Final Rule, effective September 4, 2024 (see 89 FR 63325) as a replacement for the basic version and alternate I of 552.216-70, Economic Price Adjustment—FSS Multiple Award Schedule Contracts.
The following recently issued acquisition policy impacts this information collection.
Class Deviation CD-2025-13, Revised Transactional Data Reporting (TDR) Requirements for the Federal Supply Schedule (FSS) Program, was issued on June 26, 2025. The class deviation (CD) amends the GSAM to make TDR requirements mandatory for the FSS program and includes previously approved additional TDR elements3. As a result, the pricing disclosures and sales reporting requirements covered by information collection 3090-0235 will no longer apply to the FSS program. GSA anticipates completing the full transition to TDR by the end of Year 1 of the renewal period4.
The total estimated annual public hour burden increased due to the use of updated data and the transition of the FSS program to TDR. The total estimated annual public hour burden changed-
FROM: 281,344
TO: 1,553,495 for Year 1 and 1,044,217 for Years 2 & 3
The total estimated annual public cost burden increased due to the use of updated data and the transition of the FSS program to the TDR. The total estimated annual public cost burden changed-
FROM: $18,104,484
TO: $121,766,340 and for $69,731,624 Years 2 & 3
The total estimated annual cost burden to the Government increased due to the use of updated data and the FSS program transition to TDR. The total estimated annual cost to the Government changed-
FROM: $1,721,168
TO: $4,078,150 for year 1 and $5,652,696 for Years 2 & 3
The total estimated annual government hour burden increased due to the use of updated data and the transition of the FSS program to TDR. The total estimated annual public hour burden changed-
FROM: 19,861
TO: 53,761 for Year 1 and 76,788 for Years 2 & 3
Need & Method for the Information Collection.
The information being collected is tied to the aforementioned GSAR sections and clauses. These GSAR clauses apply to GSA contracts (i.e., both FSS contractors and non-FSS contractors) whose contracts are subject to TDR requirements.
Until the GSAR is formally amended via a formal rule making to reflect the revisions made by CD-2025-13 along with other necessary revisions the below represents the TDR requirements currently codified in the GSAR:
a. Clause prescription.
GSAR section 516.506 includes the prescription for GSAR clause 552.216-75. This section and clause applies to non-FSS contracts subject to TDR requirements.
GSAR section 538.273 includes the prescription for the following GSAR clauses: Alternate I of 552.238-80; Alternate I of 552.238-81; 552.238-83; 552.238-85; and 552.238-120. This section and the clauses identified apply to FSS contracts subject to TDR requirements.
b. Clauses.
552.216-75, Transactional Data Reporting. This GSAR clause requires a non-FSS contractor to submit a Contract Access Fee (CAF) and on a monthly basis required transactional data.
Alternate I of GSAR clause 552.238-80, Industrial Funding Fee and Sales Reporting. This GSAR clause requires a FSS contractor to submit an Industrial Funding Fee (IFF) and on a monthly basis required transactional data.
Alternate I of GSAR clause 552.238-81, Price Reductions. This GSAR clause establishes the requirements around price reductions for FSS contracts subject to TDR requirements, which is different from those FSS contracts not subject to TDR requirements. Specifically, this GSAR clause allows for the FSS contractor to offer the contracting officer a voluntary price reduction at any time during the contract period. Additionally, allows the Government to request from the FSS contractor, and the FSS contractor to provide to the Government, a temporary or permanent price reduction at any time during the contract period.
552.238-83, Examination of Records by GSA. This GSAR clause requires FSS contractors to maintain certain records for purposes of the Administrator of General Services or any duly authorized representative examining any books, documents, papers and records of the contractor involving transactions related to the contractor’s contract for overbillings, billing errors, compliance with contract clauses 552.238-81, Price Reductions and 552.238-80, Industrial Funding Fee and Sales Reporting.
552.238-85, Contractor’s Billing Responsibilities. This GSAR clause allows a FSS contractor to authorize their dealer(s) to bill ordering activities and accept payment on behalf of the FSS contractor. In this case, the FSS contractor and dealer must enter into an agreement that includes, but not limited to, the dealer agreeing to maintain certain records on sales under the contractor’s GSA FSS contract. The record keeping requirement does not add any additional burden to what is already captured by Alternate I of GSAR clause 552.238-80, Industrial Funding Fee and Sales Reporting, which is covered by this information collection.
● 552.238-120, Economic Price Adjustment—Federal Supply Schedule Contracts. This GSAR clause allows FSS contractors (regardless if transactional data reporting requirements apply or not) to request economic price adjustments during contract performance. FSS contractors requesting price adjustment must submit requests that fully conform to the requirements of the economic price adjustment method and include sufficient information to support the request.
The information collected is submitted electronically (to the maximum extent possible) and is included, if applicable, within an offer or is submitted as part of contract performance.
Use of the Information.
The information collected is used by GSA in a variety of ways (e.g., data analysis, making acquisition decisions, supporting market research and price analysis). Contracting officers also use some of the data in relation to contract performance activities (e.g., processing price reduction requests). Some of the information collected is also made available for use by authorized personnel to support category management as well as other acquisition actions. For example, the transactional data collected under this information collection can be used by category managers to analyze consumption patterns, evaluate and compare purchasing channels, therefore leading to more optimal acquisitions that make better use of taxpayer dollars.
Use of Information Technology.
The Government uses information technology to the maximum extent practicable. For the purposes of this information collection, contractors are to submit the information required electronically (to the maximum extent possible).
Non-Duplication.
GSA did not identify any duplication of information being collected under this information collection. The information provided by a contractor is unique and specific to their organization and their contract.
This information is not collected elsewhere and could not otherwise be obtained.
Any similar information that may already be available to GSA cannot be used or modified to be used for the purposes described. As only a contractor knows the information that applies to their contract, specifically the information needed, if any, to respond to the GSAR clauses covered by this information collection.
Burden on Small Business.
The burden applies equally to both small businesses and other than small businesses that have a GSA contract subject to TDR requirements.
The submission of the information covered by this information collection is provided by the contractor and reflects information associated with the products or services delivered/performed by the contractor under task/ delivery orders issued against their contract or performance of their contact (e.g., obtaining transaction data or processing a contractor’s request for an economic price adjustment). A contractor submits the required information, as applicable, based on the applicable GSAR clause(s). The information requested is the minimum necessary to support the objectives of the given action.
Less Frequent Collection.
The frequency of collection is limited to the extent necessary to support the needs of the Government for purposes of supporting contracts subject to TDR requirements. The information is submitted by a contractor in relation to orders issued against their contract or performance of their contract (i.e., submission of a request for an economic price adjustment).
Not collecting this information or collecting this information less frequently would impede GSA’s ability to continue to operate the GSA FSS program and other GSA vehicles that include an IFF/CAF. Additionally, would hinder a contractor's ability to adjust pricing under their contract. The IFF/CAF covers GSA’s costs of establishing and operating government-wide contract solutions and is included in the prices ordering activities pay contractors when purchasing from these GSA vehicles. Contractors are required to report transactional data and submit requests for an economic price adjustment in accordance with the terms of their contract.
Paperwork Reduction Act Guidelines.
GSAR clause 552.216-75 and Alternate I of GSAR clause 552.238-80 require contractors to report TDR data on a monthly basis instead of a quarterly basis. In development of these regulations, GSA decided to require monthly reporting because transactional data is less valuable as time passes and because contractors commonly invoice on a monthly basis.
Consultation and Public Comments.
A 60-day notice was published in the Federal Register at 90 FR 47308 on October 1, 2025. One comment was received, however, the comment did not change the estimate of the burden.
The respondents’ comment supports the importance of the information collection and included information about an automated solution for purposes of assisting contractors with reporting. The
respondents’ input is appreciated.
A 30-day notice was published in the Federal Register at 90 FR 58560 on December 17, 2025.
Gifts or Payment.
Not applicable, GSA makes no such payments or gifts to respondents under this information collection.
Privacy & Confidentiality.
Not applicable, GSA makes no additional assurances under this information collection beyond what is already applicable to contract information (i.e., information collected is disclosed only to the extent consistent with prudent business practices, agency regulations, and applicable statutes). For example, some of the transactional data elements being collected are already available to the public (e.g., delivery/task order number/Procurement Instrument Identifier) via public databases (e.g., SAM.gov).
This information collection does not require collection of “personally identifiable information”.
GSA uses information technology to the maximum extent practicable for purposes of collecting this information.
Sensitive Questions.
Not applicable, no sensitive questions are involved under this information collection.
Burden Estimate.
Year 1
The total estimated annual cost burden to the public resulting from this information collection for Year 1 is $121,766,340. The total estimated annual public hour burden resulting from this information collection for Year 1 is 1,553,495 hours. These estimates are higher than Years 2 & 3 in order to account for the aforementioned transition of existing non-TDR FSS contracts to TDR. The transition is anticipated to be completed by the end of Year 1 of this renewal.
Years 2 & 3
The total estimated annual cost burden to the public resulting from this information collection for Years 2 & 3 is $69,731,624. The total estimated annual public hour burden resulting from this information collection for Years 2 and 3 is 1,044,217 hours.
The above total burden estimates are calculated by adding up the total for each of the GSAR clauses covered by this information collection.
These burden estimates are based on the following calculations:
Changes Due to Adjustment in Agency Estimate:
Updated numbers were used. The change in the numbers can be attributed to GSA using more recent data and the expansion of the TDR program.
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Burden per Response:
|
Time per response (hours) |
Total Estimated Annual Hours |
Cost per response |
Reporting - FSS (monthly) |
varies* |
varies* |
varies* |
Reporting - Non-FSS (monthly) |
varies* |
varies* |
varies* |
Reporting - FSS (Initial set-up) |
varies* |
varies* |
varies* |
Reporting - FSS (Initial set-up) |
varies* |
varies* |
varies* |
Reporting - FSS (Price Reduction) |
4.25 |
Year 1 - 106 Years 2 & 3 - 213 |
$392 |
Reporting - FSS (EPA) |
4.25 |
Year 1 - 2,550 Years 2 & 3 -7,650 |
$392 |
Record Keeping - (Examination of Records by GSA) |
455 |
2,275 |
$41,926 |
Third Party Disclosure |
N/A |
N/A |
N/A |
Total |
N/A |
N/A |
N/A |
*This number varies based on various factors as well as the transition to TDR. See the below information for the calculations for GSAR clauses 552.216-75 and Alternate I of 552.238-80
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Annual Burden:
GSAR clause 552.216-75, Transactional Data Reporting. The following is the estimated burden cost/hour associated with this clause*.
Initial Set-up (Manual) Estimated # of respondents per year: 14 Estimated hours per respondent: x10 Total estimated annual burden hours: 140
Estimated cost per hour: x 92.15 Total estimated annual cost burden: $12,900
Initial Set-up (Automated System) Estimated # of respondents per year: 6 Estimated hours per respondent: x 245 Total estimated annual burden hours: 1,470
Estimated cost per hour: x 92.15 Total estimated annual cost burden: $135,454
Monthly Reporting (Manual system) Estimated # of respondents per year: 2,641 Estimated hours per respondent*: x varies Total estimated monthly burden hours: 13,173
Annual reporting periods per respondent x 12 Total estimated annual burden hours: 158,070
Estimated cost per hour: x $65.58 Total estimated annual cost burden: $10,365,776
Monthly Reporting (Automated system) Estimated # of respondents per year: 1,391 Estimated hours per respondent: x varies Total estimated monthly burden hours: 5,329
Annual reporting periods per respondent x 12 Total estimated annual burden hours: 63,948
Estimated cost per hour: x $65.58 Total estimated annual cost burden: $4,193,526
Alternate I of GSAR clause 552.238-80, Industrial Funding Fee and Sales Reporting*
Year 1
New Awardees
Initial Set-up (Manual System) Estimated # of respondents per year: 241 Estimated hours per respondent: x 10 Total estimated annual burden hours: 2,410
Estimated cost per hour: x $92.15 Total estimated annual cost burden: $222,072
Initial Set-up (Automated System) Estimated # of respondents per year: 135 Estimated hours per respondent: x 245 Total estimated annual burden hours: 33,075
Estimated cost per hour: x $92.15 Total estimated annual cost burden: $3,047,725
Year 1 - Existing Non-TDR contracts transitioning to TDR
Initial Set-up (Manual System) Estimated # of respondents per year: 7,239 Estimated hours per respondent: x 10 Total estimated annual burden hours: 72,390
Estimated cost per hour: x $92.15 Total estimated annual cost burden: $6,670,440
Initial Set-up (Automated System) Estimated # of respondents per year: 2,589 Estimated hours per respondent: x 245 Total estimated annual burden hours: 634,305
Estimated cost per hour: x $92.15 Total estimated annual cost burden: $58,448,589
Year 1
Monthly Reporting (Manual system) Estimated # of respondents per year: 6,886 Estimated hours per respondent: x varies Total estimated monthly burden hours: 34,756
Annual reporting periods per respondent x 12 Total estimated annual burden hours: 417,072
Estimated cost per hour: x $65.58 Total estimated annual cost burden: $27,350,383
Monthly Reporting (Automated system) Estimated # of respondents per year: 2959 Estimated hours per respondent: x varies Total estimated monthly burden hours 13,807
Annual reporting periods per respondent x 12 Total estimated annual burden hours: 165,684
Estimated cost per hour: x 65.58 Total estimated annual cost burden: $10,865,080
Years 2 & 3
Monthly Reporting (Manual system) Estimated # of respondents per year: 10,423 Estimated hours per respondent: x varies Total estimated monthly burden hours: 46,495
Annual reporting periods per respondent x 12 Total estimated annual burden hours: 557,934
Estimated cost per hour: x $65.58 Total estimated annual cost burden: $36,587,708
Monthly Reporting (Automated system) Estimated # of respondents per year: 3877 Estimated hours per respondent: x varies Total estimated monthly burden hours 18,086
Annual reporting periods per respondent x 12 Total estimated annual burden hours: 217,032
Estimated cost per hour: x 65.58 Total estimated annual cost burden: $14,232,335
*The calculations for GSAR clauses 552.216-75 and Alternate I of 552.238-80 are based on the following5:
Category 1 .5 hours (manual) 2 hours (automated) Category 2 2.5 hours (manual) 2.5 hours (automated) Category 3 5 hours (manual) 3 hours (automated) Category 4 18 hours (manual) 4 hours (automated) Category 5 50 hours (manual) 5 hours (automated)
Category 1: No sales activity (sales of $0.00) Category 2: Sales between $0.01 and $25,000 Category 3: Sales between $25,000.01 and $250,000 Category 4: Sales between $250,000.01 and $1 million Category 5: Sales over $1 million
Category 1 100% manual system 0% automated system Category 2 100% manual system 0% automated system Category 3 90% manual system 10% automated system Category 4 50% manual system 50% automated system Category 5 10% manual system 90% automated system
GSAR clause 552.238-120, Economic Price Adjustment—Federal Supply Schedule Contracts. The following is the estimated burden hour/cost associated with this clause.
Year 1 Estimated # of responses per year: 600 Estimated burden hours per response: x 4.25 Total estimated annual burden hours: 2,550
Estimated cost per hour**: x $92.15 Total estimated annual cost burden : $234,972
Years 2 & 3 Estimated # of responses per year: 1800 Estimated burden hours per response: x 4.25 Total estimated annual burden hours: 7,650
Estimated cost per hour**: x $92.15 Total estimated annual cost burden : $704,916
Alternate I of GSAR clause 552.238-81, Price Reductions. The following is the estimated burden hour/cost associated with this clause:
Year 1 Estimated # of responses per year: 25 Estimated burden hours per response: x 4.25 Total estimated annual burden hours: 106
Estimated cost per hour**: x $92.15 Total estimated annual cost burden : $9,790
Years 2 & 3 Estimated # of responses per year: 50 Estimated burden hours per response: x 4.25 Total estimated annual burden hours: 213
Estimated cost per hour**: x $92.15 Total estimated annual cost burden : $19,581
GSAR clause 552.238-83 Examination of Records by GSA. The following is the estimated hour/cost burden associated with this clause for Years 1 through Year 3.
Estimated # of respondents per year: 5 Estimated burden hours per respondent: x 455 Total estimated annual burden hours: 2,275
Estimated cost per hour**: x $92.15 Total estimated annual cost burden: $209,632
**The estimated cost per hour is based on the task being accomplished by personnel equivalent to a GS-14, Step 5. A GSA-14, Step 5 employee hourly rate for 2025 is $92.15. |
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Estimated nonrecurring costs.
Not applicable to this information collection.
Estimated cost to the Government.
The total estimated annual cost burden and total estimated annual burden hours to the Government for Year 1 is $4,078,150 and 53,761. The total estimated annual cost burden and total estimated annual burden hours to the Government for Years 2 & 3 are: $5,652,696 and 76,788.
These estimates are based on the following:
GSAR clause 552.216-75, Transactional Data Reporting.
Estimated # of respondents per year 3,780
Estimated review time per response (hours) x 2.5
Total review time per year (hours) 9,450
Estimated cost per hour* x $65.58
Total estimated annual cost to the Government $619,704
Alternate I of GSAR clause 552.238-80, Industrial Funding Fee and Sales Reporting.
Year 1.
Estimated # of respondents per year 9,845
Estimated review time per response (hours) x 4
Total review time per year (hours) 39,380
Estimated cost per hour* x $65.58
Total estimated annual cost to the Government $2,582,427
Years 2 & 3.
Estimated # of respondents per year 14,300
Estimated review time per response (hours) x 4
Total review time per year (hours) 57,200
Estimated cost per hour* x $65.58
Total estimated annual cost to the Government $3,751,012
*The estimated cost per hour is based on the task being accomplished by personnel equivalent to a GS-12, Step 5. A GSA-12, Step 5 employee hourly rate is $65.58.
Information Technology Systems: The system needed to collect and process transactional data required under GSAR clause 552.216-75 and Alternate I of GSAR clause 552.238-80 costs GSA an average of $491,500.00, spread across a 20-year contract life cycle.
GSAR clause 552.238-120, Economic Price Adjustment—Federal Supply Schedule Contracts.
Year 1.
Estimated # of responses per year: 600
Estimated burden hours per response: x 4.25
Total estimated annual burden hours: 2,550
Estimated cost per hour**: x $77.98
Total estimated annual cost to the Government: $198,838
Years 2 & 3.
Estimated # of responses per year: 1,800
Estimated burden hours per response: x 4.25
Total estimated annual burden hours: 7,650
Estimated cost per hour**: x $77.98
Total estimated annual cost to the Government: $596,515
Alternate I of 552.238-81, Price Reductions.
Year 1.
Estimated # of responses per year: 25
Estimated burden hours per response: x 4.25
Total estimated annual burden hours: 106
Estimated cost per hour**: x $77.98
Total estimated annual cost to the Government: $8,285
Years 2 & 3.
Estimated # of responses per year: 50
Estimated burden hours per response: x 4.25
Total estimated annual burden hours: 213
Estimated cost per hour**: x $77.98
Total estimated annual cost to the Government: $16,570
552.238-83, Examination of Records by GSA. The following is the estimated burden associated with this clause.
Estimated # of audits per year: 5
Estimated hours per audit: x 455
Total estimated annual burden hours: 2,275
Estimated cost per hour** x $77.98
Total estimated annual cost to the Government $177,395
**The estimated cost per hour is based on the task being accomplished by midlevel personnel equivalent to a GS-13, Step 5. A GSA-13, Step 5 employee hourly rate is $77.98.
Reasons for changes.
Unless otherwise explained the majority of changes are a result of using current information and accounting for the transition of existing non-TDR FSS contracts to TDR during Year 1 of the renewal of this information collection.
For Item 12, an updated estimated cost per hour (i.e., hourly rate) for the GS-14, Step 5 employee was used. The hourly rate of $92.15 is based on a base salary of $67.63 per hour (see OPM Salary Table 2025-RUS, Effective January 2025), plus a fringe factor of 36.25% ($24.52) (see OMB Memo M-08-13 for use in public-private competition). The previous extension used OPM’s Salary Table from 2022, whereas this extension is using OPM’s Salary Table Effective January 2025.
For Items 12 and 14, an updated estimated cost per hour (i.e., hourly rate) for the GS-12, Step 5 employee was used. The hourly rate of $65.58 is based on a base salary of $48.13 per hour (see45 OPM Salary Table 2025-RUS, Effective January 2025), plus a fringe factor of 36.25% ($17.) (see OMB Memo M-08-13 for use in public-private competition). The previous extension used OPM’s Salary Table from 2022, whereas this extension is using OPM’s Salary Table Effective January 2025.
For Item 14, an updated estimated cost per hour (i.e., hourly rate) for the GS-13, Step 5 employee was used. The hourly rate of $77.98 is based on a base salary of $57.23 per hour (see OPM Salary Table 2025-RUS, Effective January 2025), plus a fringe factor of 36.25% ($20.75) (see OMB Memo M-08-13 for use in public-private competition). The previous extension used OPM’s Salary Table from 2022, whereas this extension is using OPM’s Salary Table Effective January 2025.
Publicizing Results.
Not applicable, results of this information collection will not be published. Information collected is used for internal purposes only.
OMB Not to Display Approval.
Not applicable, GSA is not seeking such approval for this information collection.
Exceptions to "Certification for Paperwork Reduction Submissions."
Not applicable, GSA has no exceptions to the certification statement.
Surveys, Censuses, and Other Collections that Employ Statistical Methods.
Statistical methods are not used for this information collection.
1This information collection only covers the burden associated with GSA contracts subject to TDR requirements. For example, the basic version of GSAR clauses 552.238-80 and 552.238-81 do not apply to TDR contracts and are covered by information collection OMB Control Number 3090-0235, Federal Supply Schedule Pricing Disclosures and Sales Reporting.
2An authorized deviation of this clause was used. The authorized deviation was prescribed under Class Deviation CD-2019-14, which is no longer in effect.
3TDR elements are captured within Alternate I of 552.238-80, Industrial Funding Fee and Sales Reporting
4FSS offerors and new awardees will be covered by TDR prior to this renewal period while existing FSS contractors will transition to the TDR program during Year 1 of this renewal period.
5The following information used in the calculation of the burden for these two clauses were updated: (i) the initial set-up burden hours for automated vs. manual systems increased, and (ii) the monthly reporting burden hours for automated vs. manual systems were increased for each sales revenue category (except for Automated at category 1, it remained 2 hrs). The following information used in the calculation of the burden for these two clauses remained the same as prior renewals: (i) the employee equivalents (e.g., GS-12 Step 5); and (ii) the automated vs. manual reporting systems percentages; and (iii) the categorization of contractors by monthly sales revenue (e.g., Category 1 still means No sales activity (sales of $0.00)).
| File Type | application/vnd.openxmlformats-officedocument.wordprocessingml.document |
| File Modified | 0000-00-00 |
| File Created | 2025-12-18 |