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  1. Vern, Now that's the direct approach! Thanks for checking with them. As for the USACE, I did find this document http://bit.ly/2jKs5yv which appears to be valid (someone higher up the chain than the contracting officer). The USACE policy is mandatory in the sense that it has to be in the solicitations, but compliance by the contractor is voluntary, which alleviates issues that concern me. Thanks again, while I'm twiddling my thumbs figuring out what to do you dove right into the matter. Mark
  2. Perhaps had the wrong idea about the exchange of ideas on these forums. I'm surprised to see more than one suggestion to essentially "just ask the government". If that is legitimate advice, is there a need for these forums? I was hoping the actual RFP would provide context to my inquiry. Yes, we submit certified payroll to the government already, and yes, it's electronic. Typically, it's a pdf or xls and we email them in. The "mandatory e-payroll" clause is a different beast. It is not just uploading a spreadsheet to the government's site. It requires use of a third party payroll system. It requires a system that contains the payroll data, which the government access via a unique login ID and password. Sure, we're big boys; if we have to, we can comply. It's not something that will make us give up bidding on jobs. Not sure wether to take the "get a life" bait or not. Government work is our company life, and we take our obligations very seriously. But whether or not there is authority to impose the clause is a different matter. I prefer to research an issue so I have some familiarity with the statutory and administrative context so if/when we submit an RFI or just call, we can frame the question properly. That way I won't have to just take their word for it when I receive an answer.
  3. Thanks Don, great points. I didn't know this sort of thing was prevalent. I usually here about new rules/rulemaking that impact us, but this one came out of left field. You've given me some good statutory authority to push back if we decide to. It is somewhat of a burden given that we would likely have to outsource it to a payroll company as well as maintain our existing payroll system (to keep track of fringes, sick leave, etc.) Mark
  4. All: I am trying to figure out the authority for a contracting officer to require "Mandatory E-payroll" reporting. The email indicates the clause will be used "in all NEW solicitations (stand-alone, basic IDIQ JOC and associated task orders, basic IDIQ and associated task orders)". For example: http://bit.ly/2xOSpxz at p. 74: "The contractor shall use a supplemental electronic Construction Wage Rate Requirements statute payroll processing system". The "functional requirements" seem familiar, perhaps DCAA, but I couldn't find an exact match. My research shows that the DOL encourages, but doesn't require, electronic payroll reporting. As you can see from the linked solicitation, reference is made to "compliance with far 52.222-8, payrolls and basic records and far 52.222-13" but no such mandate appears therein. I can't find anything in the congressional record, acquisition.gov, or a Navy directive authorizing use of this clause. The Army Corps has a similar clause, but it is not mandatory (PIL 2011-09). On the other hand, it doesn't seem likely that the contracting officer would draft and insert such a clause without peer review or other safeguards. Any help would be most appreciated. Excerpt from solicitation attached in case the link doesn't work. Mark SWDiv Mandatory E-payroll.pdf
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