CSP, or Commercial Sales Practices, refers to the disclosure document submitted by contractors during the GSA Schedule offer or modification process. The CSP document outlines a contractor’s pricing structure, standard discounts, terms of sale, and relationships with various customer categories in the commercial market.
The purpose of CSP disclosures is to allow GSA to evaluate whether the prices offered to the government are fair and reasonable by comparing them to the contractor’s commercial practices. CSP data is a cornerstone of the Price Reductions Clause and the Most Favored Customer (MFC) policy under the GSA Multiple Award Schedule (MAS) program.
Purpose of the CSP Document
CSP disclosures provide the GSA contracting officer with insight into how a vendor sells to its commercial, educational, non-profit, and other government customers. This information enables the Contracting Officer (CO) to:
- Establish a Basis of Award (BOA) — the customer or category used as a benchmark for price comparison
- Ensure pricing consistency and fairness — the government should receive pricing that is equal to or better than that offered to comparable commercial customers
- Negotiate discounts based on volume, terms, or market norms
- Monitor future price reductions under the Price Reductions Clause, if applicable
The CSP lays the foundation for pricing negotiations and becomes a critical reference point for the life of the GSA Schedule contract.
What the CSP Includes
The CSP format is standardized by GSA and requires detailed information on a vendor’s commercial pricing policies. Key elements typically include:
- Customer categories — such as large commercial clients, resellers, end users, or educational institutions
- Discount practices — standard, volume-based, promotional, or term-based discounts offered to each category
- Concessions and terms — such as prompt payment terms, FOB delivery, warranties, and returns
- Most Favored Customer (MFC) designation — the category of customer that receives the best overall pricing and terms
- Basis of Award (BOA) — the customer or category selected by GSA as the comparison point for future pricing changes
Vendors must certify that the information provided is current, accurate, and complete to the best of their knowledge at the time of submission.
CSP and the Price Reductions Clause
The Price Reductions Clause (GSAR 552.238-81) ties directly to the CSP disclosures. If a contractor offers better pricing or terms to its designated BOA customer during the life of the GSA contract, the government may be entitled to equivalent reductions.
However, not all contracts are subject to the Price Reductions Clause. For example:
- Transactional Data Reporting (TDR) participants are exempt from the CSP and PRC requirements
- Non-TDR contracts must maintain pricing integrity with respect to the MFC/BOA relationship
Contractors must carefully track commercial sales and notify GSA if pricing changes occur that may trigger the clause.
When CSP Is Required
The CSP disclosure is required in the following situations:
- Initial GSA Schedule proposal submission
- Adding new Special Item Numbers (SINs) or products/services
- Modifying pricing structures
- Renewing or extending a contract
Failure to provide complete and truthful CSP information can lead to serious consequences, including contract termination, audit findings, or False Claims Act violations.
Updates and TDR Exception
In 2016, GSA introduced the Transactional Data Reporting (TDR) pilot program, which allows vendors to opt out of CSP disclosures in exchange for providing monthly transactional data on sales. TDR aims to reduce administrative burden and improve pricing transparency through data analysis rather than pre-award pricing disclosures.
Key distinctions:
- CSP is required for non-TDR Schedule contracts
- TDR contractors report actual sales data instead of providing pricing history
- Participation in TDR is optional and SIN-specific, not available for all categories
Contractors should evaluate whether the CSP model or TDR model is more appropriate based on their sales complexity, pricing flexibility, and reporting capabilities.
Best Practices for Managing CSP Requirements
To remain compliant and competitive, contractors should:
- Maintain thorough internal pricing records
- Document all discounts, concessions, and terms offered to commercial clients
- Clearly identify and justify the Most Favored Customer
- Review CSP submissions before modifications to ensure continued accuracy
- Train sales and contracts staff on CSP implications and reporting triggers
Accurate CSP disclosures not only support compliance but also strengthen trust during negotiations with GSA contracting officers.
Conclusion
Commercial Sales Practices (CSP) disclosures are a foundational requirement of doing business under a GSA Schedule contract—unless exempted under TDR. They provide the basis for GSA to evaluate pricing fairness and to establish protections like the Price Reductions Clause. For contractors, CSP compliance demands transparency, careful documentation, and strategic alignment with pricing and sales practices across all markets.
