Government Contract Reporting Requirements: What did you just sign up for?

Breakout Session #: A16 Katherine Adams, Senior Contracts Manager, Accenture Federal Services

Nathan Geesaman, Experienced Manager, Baker Tilly

Date: Monday, July 25

Time: 11:15am–12:30pm

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Introduction – Reporting Requirements • Congratulations, you’ve won a government contract. Hopefully

you’ve read carefully through the contract’s reporting requirements and know you’ve signed up for!

• This presentation will aim to give you an overview of reporting requirements that may be included in your government contract. We will describe each requirement and discuss the regulatory citation, frequency of reporting, and estimate of contractor effort.

• Note - This is not an exhaustive list of all reporting requirements. Always read the contract to fully understand all of its requirements.

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Introduction – Reporting Requirements • Government contracts almost always come with reporting

requirements proscribed by either contract language or incorporated clauses.

• They serve a number of purposes including: • Maintaining an accurate contractor database [CPARS] • Tracking sales [IFF] • Measuring progress against goals [Subcontracting] • Maintaining accountability [ICP] • And many other reasons

Incurred Cost Proposal (ICP) • Requirement Summary

– Required if your contract includes FAR 52.216-7 - Allowable Cost and Payment – An adequate submission include fifteen (15) schedules as described in FAR

52.216-7(d)(2)(iii)

• Frequency – Due annually six (6) months after contractor’s fiscal year-end

• Estimate of Effort: – Varies depending on contractor’s accounting and CLM systems and how they

tracks costs, billing, and contract metadata

• Notes – Contain information that is important in finalizing indirect cost rates for the fiscal

year in question – Reasonable extensions, for exceptional circumstances, may be requested in

writing to the Contracting Officer (CO). – Supplemental information may be required during the audit process. The list of

possible requirements is broad and is outlined in FAR 52.216-7(d)(2)(iv)

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GSA Schedule Sales and IFF (Industrial Funding Fee) • Requirement Summary

– Sales Report: Contractor must report the total dollar value of sales made pursuant to the contractor’s General Services Administration (GSA) Schedule for the calendar quarter

– IFF Remittance: Contractor must remit IFF along with their sales report. IFF is calculated as a percentage (0.75%) of the sales reported

• Frequency – Quarterly within 30 days after the end of the reporting quarter

• Estimate of Effort: – Varies depending on contractor’s accounting system and how it tracks GSA

Schedule sales

• Notes – Reportable sales are defined in GSAR 552.238-74(a)(3) as sales of contract

items made to authorized users – Sales made to state and local governments under Cooperative Purchasing

authority shall be counted as reportable sales for IFF purposes – Failure to remit full IFF constitutes a contract debt to the US Government under

the terms of FAR 32.6 – Must submit a zero dollar report if there are no sales during the quarter

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Small Business Subcontracting Plan • Requirement Summary

– Contractors must submit reports measuring progress towards goals set forth in their subcontracting plan per FAR 52.219-9. The type of plan (i.e. Commercial vs Individual) and contract language will determine which reports are required

• Individual Subcontract Report (ISR) under individual plan • Summary Subcontract Report (SSR) under individual plan • Summary Subcontract Report (SSR) under commercial plan

– Despite some variations, reports generally must include: • Cumulative subcontracting spend separated between small and large business concerns • Cumulative small business subcontracting awards separated by type (e.g. Women-owned Small

Business (WOSB), Veteran-owned Small Business (VOSB). • Other administrative information (Vendor Name, Vendor Address, DUNS etc.)

• Frequency – ISR under individual plan - semi-annually within 30 days of 3/31 and 9/30 – SSR under individual plan – NASA and DoD (semi-annually within 30 days of

3/31 and 9/30) and Civilian (annually within 30 days of 9/30) – SSR under commercial plan - annually within 30 days of period ending 9/30

• Estimate of Effort: – Varies depending on contractor’s accounting system and how it tracks

subcontractor/vendor spend

• Notes – Reports are required when due regardless of subcontracting activity (i.e. must

submit zero dollar reports if there is no subcontract spend)

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Government Property • Requirement Summary

– Contractors are required by FAR 52.245-1 to maintain an accurate database of Government-furnished property (GFP)

– Department of Defense requires contractors to report Government-furnished property at a slightly more detailed level to the IUID Registry as described in DFARS 252.211-7007

• Frequency – GFP reports per FAR 52.245-1 due as requested by CO – GFP record updates in the IUID Registry per 252.211-7007 should be

performed as transactions occur or as stated in contractor’s property management tool

• Estimate of Effort: – Varies depending on contractor’s asset/property management system

• Notes – Prior to January 1, 2014 contractor was only required to report serially managed

GFP with a unit-acquisition cost greater than $5,000 – Several exceptions to the rule are described in DFAR 252.211-7007(c)

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Service Contract Reporting • Requirement Summary

– Basic service contract reporting requirements are established in FAR 52.204-14 – Separate requirements described in FAR 52.204-14 relate specifically to

reporting requirements for Indefinite-delivery contracts – Agencies review the service contract reports submitted for reasonableness and

consistency

• Frequency – Reports under both FAR 52.204-14 and FAR 52.204-15 are due annually by

October 31 for the period October 1 - September 30 and must be submitted on sam.gov

• If the agency believes revisions are warranted they must notify the contractor no later than November 15

• Contract shall revise, or provide rationale supporting, the report by November 30

• Estimate of Effort: – Varies depending on contractor’s accounting system and how it tracks labor

hours and billing

• Notes – CO will make failure to comply part of a contractor’s performance information

under FAR 42.15 – Civilian executive agencies have a requirement to prepare an annual inventory

of service contracts – DoD has a separate reporting tool (eCMRA) and associated requirements we

will cover in the next slide

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Enterprise-wide Contractor Manpower Reporting Applications (eCMRA) • Requirement Summary

– Reporting required by DAR 52.237-9001 – DoD specific system set up to capture service contract labor information in one

of four systems (Army, Navy, Air Force, All Other Defense Components) – System and Contracting Officer’s responsibilities spelled out in detail in FAR

37.1

• Frequency – Contractor must annually input all labor hours into eCMRA.mil no later October

31 for the previous fiscal year

• Estimate of Effort – Varies depending on contractor’s accounting system and how it tracks labor

hours and billings

• Notes – Exemptions for utilities, construction (including repair and maintenance), and

telecommunication services that do not include discrete labor hours and dollars

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Government-wide Acquisition Contracts (GWAC) • Requirement Summary

– GWAC reporting requirements are primarily established to support contractor payment of access fees to the agency maintaining the GWAC

– GSA managed GWACs (Alliant II, VETS, STARS II etc.) have a Contractor Access Fee (CAF) set at 0.75%

– NIH managed GWAC CIO-SP3 has a NIH Contract Access Fee (NCAF) set at 0.65% and for CIO-SP3 SB set at 0.55%

• Frequency – GSA managed GWACs

• Order award and modification information due within 30 days after the month the document was signed by the Ordering Contracting Officer (OCO)

• CAF and invoice data due to GSA within 30 days after the end of the reporting quarter • Close-out report and Cost Accounting and Earned Value Management Systems checklist due

annually by May 30th of each year – NIH CIO-SP3

• Order award and modification information due within 10 calendar days of receipt by the contractor • NCAF and other administrative reports are due quarterly by the 15th day of the month following

calendar quarter end

• Estimate of Effort: – Varies depending on contractor’s accounting system and how it tracks order/mod

information and billing/payment of CAF and NCAF

• Notes – Failure to remit CAF to GSA in a timely manner will constitute a contract debt to the United

States Government under the terms of FAR 32.6

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Contractor Performance Assessment Reporting System (CPARS) • Requirement Summary

– Used to maintain a past performance database for contractors – The system is described along with the Contracting Officer’s responsibilities in FAR 42.15 – Contracting Officer must complete an assessment of a contractor in the system

• Frequency – Assessments completed annually, FAR 42.1502(a), by Government – Contractor has up to 14 calendar days from notification to submit comments, rebut

statements or provide additional information in the system

• Estimate of Effort: – Varies depending how much comment the contractor decides to input about their past

performance assessment ratings

• Notes – No proscribed penalty for contractor not responding to feedback in CPARS system – Information in the CPARS system can be used by CO’s when making contract award

decisions – System is to only be used for UNCLASSIFIED information

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Conclusion • Understand reporting requirements

before bidding • Set up internal systems to comply with

reporting requirements • Remember to read your contract’s

requirements carefully

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• Katherine.A.Adams@accenturefederal.com

• Nathan.Geesaman@bakertilly.com

Contact Information