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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!
I would be interested if anyone saw this proposed rule when posted and commented as to it potential impact on the Prime and Subcontractor reporting needs. For one I think it lacks a defined definition of "services" and when I reviewed the CMRA website it would appear that subcontractors would have to have registered within SAM in order to report, which I think brings another issue into account as many "subs" don't want to be primes and as such do not wish to be registered in various government databases. https://www.federalregister.gov/articles/2014/06/05/2014-12810/defense-federal-acquisition-regulation-supplement-service-contract-reporting-dfars-case-2012-d051 Any thoughts on what this may do to the reporting burden of an already burdensome environment for contractors? For reference: CMRA website - https://afcmra.hqda.pentagon.mil