GSA is expanding TDR expectations for labor-based services contractors, and services reporting will require much more structure than simply entering monthly sales totals.
The latest GSA TDR guidance for services focuses on how contractors should report Labor Hour, Time & Materials, and Firm Fixed Price orders in SRP. The key message is clear: reporting accuracy depends on matching each sale to the right order, SIN, order type, unit measure, deliverable description, and customer code.
For Labor Hour and T&M orders, contractors should be ready to report at the labor category level, including hourly rate, quantity of hours, worksite, order type, and applicable SIN. GSA also emphasized the importance of using UCIDs to connect internal labor names to the approved GSA catalog/price list.
For Firm Fixed Price orders, the reporting approach is different. Contractors are not required to break out labor category hourly rates. Instead, the focus is on matching the invoice description in the Description of Deliverable field, using the correct unit measure, and uploading PWS/SOO/SOW documents for new awards over $1 million.
For product contractors, GSA is adding stronger language around obsolete ICT products, EOS dates, and availability of security This creates a practical compliance challenge: many contractors’ accounting systems, invoices, internal labor codes, and approved GSA price lists are not structured the same way.. If an item appears obsolete or has a projected EOS date of three years or less, GSA may request additional information. Contractors should be ready to support their catalog data with documentation.
Contractors should start reviewing:
- Whether labor categories match the approved GSA price list
- Whether internal codes can be mapped to UCIDs
- Whether order numbers/PIIDs are captured correctly
- Whether FFP invoices provide usable service descriptions
- Whether SCLS labor lines include the required wage determination format
- Whether mixed orders separate products, labor, T&M, and FFP correctly
TDR for services is not just a reporting change. It is a data quality and contract administration process that touches accounting, invoicing, catalog management, and order documentation.
The best time to clean up the reporting structure is before the first required submission, not after SRP errors, missing fields, or inconsistent invoice descriptions create compliance issues.
I think the distinction between reporting requirements for Labor Hour/T&M orders and Firm Fixed Price orders is something many contractors may overlook. It seems like reviewing invoice descriptions and unit measures now would be much easier than trying to correct SRP reporting issues after submissions have already started.
Many companies have accounting and timekeeping systems that were never designed around GSA reporting. Aligning everything before reporting begins could save a lot of rework later.