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52.204-10 Reporting Requirements and SAM


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My company has two prime contracts: One is a CPFF TO under a IDIQ vehicle and the other is a CPAF single award contract. Neither of these contracts include 52.204-10 Reporting Executive Compensation and First-Tier Subcontract Awards. Both do, however, include 52.204-13 System for Award Management Maintenance, and one of the reps and certs within SAM is 52.204-10. Based on this, I have two questions: 

  1. Since 52.204-13 is included, we do have to complete the certification for 52.204-10 in SAM. BUT, since 52.204-10 is not included as a contract clause, my firm does not have to complete any reporting in FSRS, correct? I want to ensure we are not negligent on any reporting requirements. 
  2. What are possible reasons why the contracts don't include this clause? Looking at the clause and 4.1403(a), it seems like they should be included. 

Thanks!

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Not sure of the reason you are asking here rather than ask the KO. If the answer is yes do the report, you will be reimbursed, right?

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We are not concerned with the costs or time associated with doing the reporting, more-so with understanding the requirement and if it is applicable or not. Since it is not in the contract, it appears obviously inapplicable, but I was seeking insight from this group on why it may not have been included in the awards, and if this is common. 

I like to understand the "why" behind things, and speaking with colleagues and other contracting professionals has always proved more fruitful than asking KOs. 

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