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Guys & Gals This is a question I have based on my current contracting center procedures on reporting Manual Action - Standalone CAR's for BPA calls under $10K. Keeping in mind that we are located overseas, FAR 7.107 Service Contract Labor Standards does not apply for services contract therefore our micropurchase threshold for services is bumped to $10K. So, why do we report Manual Action Report - Standalone CAR's for BPA calls under $10K? When: *** PGI 204.606 Reporting data. (A) An individual CAR is required to be reported for each of the following types of awards regardless of the estimated value of the awards (5) Task and delivery orders and calls issued under any agreement or indefinite-delivery contract (including Federal Supply Schedules, Governmentwide acquisition contracts, or multi-agency contracts). *** 4.601 Definitions. As used in this subpart- “Contract action” means any oral or written action that results in the purchase, rent, or lease of supplies or equipment, services, or construction using appropriated dollars over the micro-purchase threshold, or modifications to these actions regardless of dollar value. Contract action does not include grants, cooperative agreements, other transactions, real property leases, requisitions from Federal stock, training authorizations, or other non-FAR based transactions. “Contract action report (CAR)” means contract action data required to be entered into the Federal Procurement Data System (FPDS). *** FPDS-NG: What’s reported to FPDS-NG? Contracts whose estimated value is $10,000 or more. Every modification to that contract, regardless of dollar value must be reported to FPDS-NG. Any other interpretations, thoughts, suggestions? Thanks ROD
Company needs to report a cyber security incident under DFARS 252.204-7011. Reporting is required within 72 hours. I have two questions: Are there penalties or other adverse consequences for late reporting? Before the Company can report, an employee must obtain a DoD-approved medium assurance certificate and this appears to take a couple days. That is a significant delay when you're sprinting toward a 72-hours deadline. Do most companies sign up for this certificate in advance? I did not see reference to it in the NIST SP 800-171. Thanks in advance for any insight! Best, Nena
Hi All, I've just received a mod to an existing contract that adds a requirement for Contractor Manpower Reporting to a DOD contract that is being administered by a non-DOD agency. The language in the mod states that the reporting will be done at no additional cost to the Government. However, my recollection of doing this type of reporting is that it can be fairly burdensome. I also recall that it was a direct charge to the contract. My questions are: 1. As this is a CPFF contract, should the costs incurred for doing the reporting be captured as direct labor or indirect labor? 2. If the costs should be captured as indirect labor, would the language prohibiting the reporting from being charged to the Government make it an unallowable cost? Thanks!
Our SBA just notified us that: "If the contract is modified and the dollar value goes up or down the subcontracting plan goals need to be renegotiate to reflect the dollar change and the percentages that may be effected do the change. This will also be reflected in the eSRS reports." This doesn't make sense to me. My interpretation of FAR 19.705-2 and 19.702 leads me to believe that it must meet a certain dollar threshold and subcontract opportunites must exist. That means we would be negotiating the SB goal dollars on a $3k mod. Background on our contract, $232M CPIF. Am I missing something or is the SBA right?