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What requires DoD contractors to report service contract manpower? I see nothing in the FAR or DFARS implementing such a policy or prescribing a clause to enforce the requirement in contracts. There was a proposed DFARS rule (DFARS Case 2012-D051) that was closed and rolled into another proposed rule (DFARS Case 2018-D063), which is where we stand now.

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Is this what you’re looking for?

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

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

I don’t believe the draft DFARS clause is in effect

https://www.federalregister.gov/documents/2020/06/05/2020-11754/defense-federal-acquisition-regulation-supplement-data-collection-and-inventory-for-services

Several agencies drafted their own interim clauses requiring contractors to submit data rather than agencies guessing.  So the answer, I guess, is nothing except for agency specific clauses or agencies just asking contractors to voluntarily submit the information.  An example is:

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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12 hours ago, formerfed said:

Several agencies drafted their own interim clauses requiring contractors to submit data rather than agencies guessing.  So the answer, I guess, is nothing except for agency specific clauses or agencies just asking contractors to voluntarily submit the information.

That is what I suspected. However, it looks like those agencies didn't comply with the DoD Clause Control Policy at DFARS PGI 201.301(b). There's nothing in their chapters of Title 48 of the CFR on this topic.

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For those Contractor personnel that work in "SAM" for a living and do not always read the contract terms or obtain negative direction from the contracts function as to contract applicability of the reporting, the SAM Guidebook for Service Contract Reporting states as follows:

"DoD contracts pulled for FY20 reporting are those where (1) period of performance indicates that performance occurred during FY20, (2) the product service code (PSC) reported is in one of the identified category management areas, (3) were in excess of $3M in obligations or deobligations reported during FY20."

I am guessing that SAM "pulls" without necessarily checking to determine whether there is a DOD clause in the contract that requires such reporting. 

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On 1/5/2021 at 6:37 PM, Don Mansfield said:

What requires DoD contractors to report service contract manpower? I see nothing in the FAR or DFARS implementing such a policy or prescribing a clause to enforce the requirement in contracts. There was a proposed DFARS rule (DFARS Case 2012-D051) that was closed and rolled into another proposed rule (DFARS Case 2018-D063), which is where we stand now.

Don et al, I am confused about your specific question. If the clause at 52.204-14 or 52.204-15 is in the contract, it requires the contractor to report service contract manpower.

If a DoD agency doesn’t include the clause per the “not required” wording in the prescriptions at 4.1705 (a) or (b), as applicable, then FAR or DFARS don’t appear to require service contractors to report manpower.

Are you asking what other prescription,  authority or DoD policy requires DoD KO’s to include one of those clauses or other clauses?

Sorry for my ignorance. It seems from the legislation and policies referenced above that DoD and non-DoD agencies are required to report certain specific service contract manpower, which I assume would be mined from the service contractor reports in a database [EDIT: or the agency would estimate or otherwise develop the data].

Are you referring to some [EDIT:more] specific service contract “manpower” (“personpower”, “womanpower”, or whatever is currently politically correct) data [EDIT: beyond that required by the above referenced clauses or just the general manpower reporting]?

Edited by joel hoffman
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For instance, formerfed’s referenced legislation at https://uscode.house.gov/view.xhtml?req=(title:10 section:2330a edition:prelim)  requires the DoD to establish a data collection system far more specific than the general service contract manpower data required by the above referenced clauses.

Thus, jtolli’s reference to  inclusion of the clause at 52.204-14 (or presumably the clause at 52.204-15 for ID/IQ service contracts) wouldn’t necessarily provide the detailed data required of contractors on certain DOD service contracts. Of course, I’m not familiar with the data input format that might be required by any specifically required governments input database.

Again, I apologize for not being up to date on the various government provided data input formats, if any.

 

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@joel hoffman,

FAR subpart 4.17 implements section 743(a) of Division C of the Consolidated Appropriations Act, 2010 (Pub. L. 111-117) and prescribes FAR 52.204-14 and -15. This statute does not apply to DoD. DoD is in the process of revising the DFARS to incorporate Service Contract Reporting pursuant to the statute that formerfed cited. That rule is not yet final.

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