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DFARS Service Contract Reporting - Proposed Rule

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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

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