I'm accustomed to completing executive compensation forms, reps & certs, and other related forms when I receive a subcontract from a prime contractor. Starting about two years ago we started getting awarded our first few prime contracts... these contracts are currently in the first or second option year, and we have been getting great CPARS ratings.. great!
In reviewing some internal processes during a new prime contract award I came across a clause I wasn't fully familiar with - 48 CFR 52.204-10 Reporting Executive Compensation and First-Tier Subcontract Awards. I had only seen this in our subcontracts, and typically based on our small business status (SDVOSB) we were/are largely exempt. Upon review of the clause I realized that there has been no one reporting the required data on fsrs.gov, and upon further review of 48 CFR 52.204-14 Service Contract Reporting Requirements, no one has been reporting in sam.gov either (though our sam.gov info is up to date).
We need to get this reporting within compliance. We dutifully complete the yearly Contractor Manpower Reporting, but these others have obviously been overlooked. Are there any things I should be aware of as I start to get this data reported? Does the latency pose any issues/call for review? Any inherent concerns? I would like to be more knowledgeable in this area so that I may undertake all responsibility involved from here out.