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Hello,

I'm accustomed to completing executive compensation forms, reps & certs, and other related forms when I receive a subcontract from a prime contractor. Starting about two years ago we started getting awarded our first few prime contracts... these contracts are currently in the first or second option year, and we have been getting great CPARS ratings.. great! 

In reviewing some internal processes during a new prime contract award I came across a clause I wasn't fully familiar with - 48 CFR 52.204-10 Reporting Executive Compensation and First-Tier Subcontract Awards. I had only seen this in our subcontracts, and typically based on our small business status (SDVOSB) we were/are largely exempt. Upon review of the clause I realized that there has been no one reporting the required data on fsrs.gov, and upon further review of 48 CFR 52.204-14 Service Contract Reporting Requirements, no one has been reporting in sam.gov either (though our sam.gov info is up to date). 

We need to get this reporting within compliance. We dutifully complete the yearly Contractor Manpower Reporting, but these others have obviously been overlooked. Are there any things I should be aware of as I start to get this data reported? Does the latency pose any issues/call for review? Any inherent concerns? I would like to be more knowledgeable in this area so that I may undertake all responsibility involved from here out.

Much appreciated,

-slow

 

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Two thoughts.

1. Better to get compliant now rather than worry about how things might look.

2. Compliance with 52.204-10 is checked during CPSRs. You may not qualify for a CPSR now, but you will one day. It would be smarter to have good habits in place before that day comes.

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Hey H2H,

Roger that. We don't currently have any government approved systems as we have never had a DCAA/DCMA audit. We attempt to maintain our systems as ones that would be approved in event of an audit, but as you can see there are some things that yet remain to be implemented

We were awarded a spot on a MAC IDIQ which required us to obtain a Certificate of Competency from the SBA, but my understanding is that the certificate of competency doesn't constitute an approved system. That contract states that we will need a gov't approved accounting system in order to invoice against a DO/TO under the IDIQ, and to my knowledge a contracting officer won't request an audit for you until you have an actual DO/TO on the IDIQ... so perhaps a DCAA and/or DCMA audit aren't too far off. I am using some NCMA materials to help prepare for those eventualities.

Thank you,

-slow

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Slowcountry,

Just checking...I take it that these services are not considered a commercial item, (i.e., they do not include FAR clause 52.212-5 or its alternate), is that correct? 

 

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