I am hoping you, my esteemed fellow Contracts administrators, can shed some light on reporting requirements for subcontractors under FAR 52.204-10(d)(2) (ii) "amount of the subcontract award".  If the subcontract contains a base year and several option years, in the first FFATA report submitted in the FSRS system, do you report the value of the base year only or the total value (base + all option years)?  If reporting the total value, it then seems that the Prime Contractor would not need to report again when option periods are exercised because the value listed in the originally submitted FFATA report would have the total value?  Looking forward to hearing your understanding/interpretation of how the requirement is actually executed via reporting requirements.

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1.108 FAR conventions.

The following conventions provide guidance for interpreting the FAR:

      (a) Words and terms. Definitions in part  2 apply to the entire regulation unless specifically defined in another part, subpart, section, provision, or clause. Words or terms defined in a specific part, subpart, section, provision, or clause have that meaning when used in that part, subpart, section, provision, or clause. Undefined words retain their common dictionary meaning.

      (b) Delegation of authority. Each authority is delegable unless specifically stated otherwise (see 1.102-4(b)).

      (c) Dollar thresholds. Unless otherwise specified, a specific dollar threshold for the purpose of applicability is the final anticipated dollar value of the action, including the dollar value of all options. If the action establishes a maximum quantity of supplies or services to be acquired or establishes a ceiling price or establishes the final price to be based on future events, the final anticipated dollar value must be the highest final priced alternative to the Government, including the dollar value of all options.

      (d) Application of FAR changes to solicitations and contracts. Unless otherwise specified-

           (1) FAR changes apply to solicitations issued on or after the effective date of the change;

           (2) Contracting officers may, at their discretion, include the FAR changes in solicitations issued before the effective date, provided award of the resulting contract(s) occurs on or after the effective date; and

           (3) Contracting officers may, at their discretion, include the changes in any existing contract with appropriate consideration.

      (e) Citations. When the FAR cites a statute, Executive order, Office of Management and Budget circular, Office of Federal Procurement Policy policy letter, or relevant portion of the Code of Federal Regulations, the citation includes all applicable amendments, unless otherwise stated.

      (f) Imperative sentences. When an imperative sentence directs action, the contracting officer is responsible for the action, unless another party is expressly cited.

Emphasis added.

On 8/10/2022 at 10:14 AM, LeighHar said:

I am hoping you, my esteemed fellow Contracts administrators, can shed some light on reporting requirements for subcontractors under FAR 52.204-10(d)(2) (ii) "amount of the subcontract award".

You may consult the Federal Funding Accountability and Transparency Act Subaward Reporting System Awardee Guide (FSRS) at https://www.fsrs.gov/

I have looked at the FSRS Awardee Guide.  The FSRS guide only takes you the steps of entering data in the system.  There is nothing about the amount to include (i.e. full award value versus base and each exercised option year).  I'm hoping in this forum, others can tell me what process is used for your reporting or share information that you might have found in researching the topic.  

@here_2_help, that is super helpful. Thank you!  Based on this, I would assume that you would only need to report then once....technically once a year if all senior executive staff members stay the same but their salaries are adjusted annually at your entity's normal annual performance review and increase process, as an example.  In keeping with this same example I used, any deviations outside of that, such as a promotion or mid year increase would then prompt you to report again for all subcontractors under your award (assuming your entity's executive compensation is not public knowledge and the other requirements are applicable - i.e. 80% of gross revenue and 25 million or more from the fed gov).  Does this logic make sense?

@LeighHar, I am from the contractor side and agree with your interpretation (1 report for base + all option values and no further reporting required when options are exercised per the awarded contract.)

Thank you Neil!

I recently learned of a contractor who, during a CPSR audit, received a finding for not reporting ExecComp when funding mods were issued.  This contractor, like most in industry, reported ExecComp at the ceiling value vs. funded value.  Reason given by the DCMA analyst was that it was to be reported when "obligated", i.e., each time a funding mod, within the ceiling value, was issued.   All the contractors I know report at the ceiling value and then annually thereafter.  Has anyone else heard of having to report at the "funded" value?

I have heard of CPSR findings being inconsistent between different review teams. It's almost like they make this stuff up as they go along.