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Contractor Manpower Reports


tjsmith1957

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Under a FFP type contract as awarded DARPA flowed down the Manpower Reporting requirements. I have 3 questions:

 

(1) Is a Manpower Report required under a FFP type agreement?

(2) If the answer above is yes. If a contractor does not have their employees enter in time in a system how would they report the Manpower?

(3) Is a Prime Contractor required to have a timekeeping system for the employees supporting a government contract 

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4 hours ago, tjsmith1957 said:

Under a FFP type contract as awarded DARPA flowed down the Manpower Reporting requirements. I have 3 questions:

 

(1) Is a Manpower Report required under a FFP type agreement?

(2) If the answer above is yes. If a contractor does not have their employees enter in time in a system how would they report the Manpower?

(3) Is a Prime Contractor required to have a timekeeping system for the employees supporting a government contract 

Nobody will be able to answer this question with certainty unless they’ve read the contract or you provide some more details.

We can make some assertions based on DARPA being a Defense Agency, but we don’t even know if it’s a FAR-based contract. If it is a DoD FAR-based contract it may include ECMRA (Enterprise Contractor Manpower Reporting Application) or SCR (service contract reporting) requirements depending on when it was awarded. For example, ECMRA applied to FFP contracts. ECMRA provided instructions on what contractors needed to report. The what should help determine the how.

What manpower requirement was flowed down? How? Is your inquiry about a prime contract issued by DARPA?

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Yes this is a FAR based contract. It does not include ECMRA or SCR. It was awarded 8/31/2020. The below is what was flowed down in the actual contract award. The contract as awarded is a prime and it is about administration and how to provide the report if there is no timekeeping system etc.

CONTRACTOR MANPOWER REPORTING
The contractor shall report ALL contractor labor hours (including subcontractor labor hours) required for performance of services provided under this contract via the following secure data collection site: www.ecmra.mil. Reporting inputs will be for the labor executed during the period of performance during each Government fiscal year (FY), which runs October 1 through September 30. While inputs may be reported any time during the FY, all data shall be reported no later than October 31 of each calendar year.

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8 hours ago, tjsmith1957 said:

It does not include ECMRA or SCR. It was awarded 8/31/2020. The below is what was flowed down in the actual contract award.

CONTRACTOR MANPOWER REPORTING
The contractor shall report ALL contractor labor hours (including subcontractor labor hours) required for performance of services provided under this contract via the following secure data collection site: www.ecmra.mil. (emphasis added)

ECMRA was de-commissioned as of COB June 19th, 2020. I recommend contacting the contracting officer for instructions. I presume they will be modifying the contract.

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  • 2 weeks later...

See this regarding DoD service contracting manpower reporting.

https://www.acq.osd.mil/dpap/policy/policyvault/USA002426-20-DPC.pdf

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According to the applicable law at 10 USC 2330a (c)(2)(E):

”(E) The number of contractor employees, expressed as full-time equivalents for direct labor, using direct labor hours and associated cost data collected from contractors (except that estimates may be used where such data is not available and cannot reasonably be made available in a timely manner for the purpose of the inventory).

See: 

https://uscode.house.gov/view.xhtml?req=(title:10 section:2330a edition:prelim)

It seems to me that estimating the basic information shouldn’t be a big burden. After all you ARE paying each employee and/or subcontractor, aren’t you?  It would be seemingly an inherent responsibility of any contractor to know who their employees are and how many of them there are.  I admit that I don’t know the extent of the info needed from contractors other than estimates* of FTE’ equivalents to meet the Congressional intent of the reporting. The rest of the info should logically be government generated.

*Estimates are seemingly allowable by law in the situation described in the original post, especially where the solicitation didn’t address the requirement.

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