Price Reductions Are Dead; Long Live Price Reductions

Sheppard Mullin Richter & Hampton LLP
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You no doubt have heard by now about GSA’s 23 June effort to “embrace modern technology while moving away from outmoded practices” – specifically, its implementation of the new Transactional Data Reporting Rule (“TDR Rule”) and its concurrent elimination of the Price Reductions Clause (“PRC”) and the Commercial Sales Practices Format (“CSPF”). See 81 Fed. Reg. 41104 (June 23, 2016). The new rule covers certain GSA Multiple Award Schedules as well as the Agency’s GWAC and IDIQ contracts. As it represents the most significant change to the GSA MAS program since 1994 (when GSA removed federal sales as a PRC trigger), the new rule has the potential to change significantly the way Schedule contractors (and others) do business; hence, my willingness to interrupt your otherwise enjoyable day with a treatise on GSA Schedule contracting.

Please see full publication below for more information.

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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations. Attorney Advertising.

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