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Laura Hoey

Contract Manpower Reporting

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My office received 12 new contracts, that will all require CMR; something we have never been required to do. One question we have is: Is the Prime responsible for reporting all Subcontractor data, or merely informing Subcontractors of their responsibility to report? DFAR 52.237-9001 states: 

"The contractor shall ensure ALL contractor labor hours (including subcontractor labor hours) required for the performance of services provided under this contract are reported via a secure data collection site."

The first sentence of the next paragraph reads: "The contractor (and all subcontractors providing direct labor under this contract) shall report..." 

Is it standard practice for the Prime to collect all Subcontractor data and perform the reporting, in order to "ensure" it takes place? 


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12 hours ago, Laura Hoey said:

DFAR 52.237-9001 states

Could you check your citation?  You write, "DFARS," which suggests the clause should be in the DFARS, but then you say it is in Part 52 (rather than 252) which suggests it might be in the FAR; but then the clause number ends is a number greater than 9000, which suggests it is a clause in a supplement "below" the DFARS (like the Army's supplement).

Toward answering your question, though, I would look for a reference in your contracts to "eCMRA" or "Electronic Contract Reporting Application."  If it is there, I would look to the instructions at the website, https://ecmra.mil.  If not, I would ask the Government contracting officer.

While my source may be out of date, it appears eCMRA is built on the assumption that the prime would flow down the reporting requirement to its relevant subcontractors.  A FAQ I found states:

  1. Who is required to report data relevant to services provided by a subcontractor?

    Subcontractors are required [sic] to enter contract-level information. Prime contractors must enter their data first. If the contract information has not been entered, the subcontractor should contact the prime contractor. The prime has overall responsibility for ensuring sub-contractors enter their respective data.


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