‘Tis the season of new Government Contract Awards! It’s also the month where there are many Government Contract Reports due either to the Prime or Government.
Here are three of the more common contract requirements, their purposes, and why they’re important to the Government.
Electronic Subcontracting Reporting System (eSRS) – FAR 52.219-9 – The Government requires that if an “other than small” (in layman’s terms — medium or large sized) business receives a contract that is over $700,000 (except for construction where the limit is $1,500,000), a small business subcontracting plan is included in the proposal. The small business subcontracting plan becomes part of the contract upon award. With some exceptions (read your contract), it is due semi-annually for the periods October 1- March 31 and October 1-September 30. The reports are due 30 days after the reporting period ends, April 30 and October 30, respectively.
The data provides an annual summary of subcontracts to the Government for each Federal Government Agency and is used by the Small Business Association (SBA) for the Subcontracting Achievement Report prepared for the President and Congress.
Service Contract Reporting – FAR 52.204-14 or 15 – The Office of Management and Budget (OMB) requires Federal Government contractors to report their service contracts annually by October 31 for the previous fiscal year in the System for Award Management (SAM) if (1) they have a cost-reimbursement, time-and-materials, or labor-hour contract above the simplified acquisition threshold (SAT) of $150,000 or (2) a fixed-price contract with a minimum of $500,000 if issued in FY 16 ($1 million if awarded in FY 15 and $2.5 million if awarded in FY 14). IDIQ contract reporting is determined by cumulative expected dollar value and type of orders issued. First-tier service subcontracts are also included in this report.
The data provides an annual accounting and inventory of services performed for the Government in the previous fiscal year.
Enterprise-wide Contractor Manpower Reporting Applications (eCMRA) – DAR 52.237-9001 – This is Required for contracts involving services, including contracts for supplies with services at a DoD military installation or other location, or for the benefit of the DoD, regardless of contract dollar value. Exemptions from this requirement include utilities, construction, and telecommunications services that don’t include direct labor hours and dollars. The report is due no later than October 31 for the preceding fiscal year in http://www.ecmra.mil/.
This report helps the Government capture the DoD workforce composition and allows for informed workforce staffing decisions, oversight, and accountability.
If you want help checking and tracking your contract requirements or have contract management questions, contact Streamline.
This blog is for informational purposes only. None of the content is, or will be deemed to constitute legal opinions or legal advice.