Feds want greater details in contractors' time and costs reporting

Rules would help agencies better manage the incoming information.

Federal officials continue their efforts to draw a clearer picture of the government’s blended workforce from reports on company services based on type of contract and dollar value, a revised proposed rule issued May 2 reveals.

Officials have proposed more detailed reporting requirements from contractors that have cost-reimbursement and time-and-materials services contracts — the riskiest types compared with contracts with a set price, according to an addition to the proposed rule initially issued April 20.

If a company has a cost-reimbursement or a T-and-M services contract, it would have to report its hours of work as low as the $150,000 simplified acquisition threshold, which allows agencies to make purchases without the lengthy formal procedures of purchasing.

Read the initial proposal.

Read the addition to the proposal.

For contracts with a set price, contractors would have to report their work based on a phased-in approach laid out in President Barack Obama’s fiscal 2011 budget. Requirements would be set at $5 million in fiscal 2011 and then declining steadily to $500,000 in fiscal 2014, according to the revised notice. The expected result is that agencies would be able to better manage the incoming information.

Companies with the riskier types of contracts have historically tracked information on their work hours to invoice the government, but under the new proposal they would be required also to report that information to the agency.

For indefinite-delivery, indefinite-quantity contracts that issue task and delivery orders, the reporting threshold would be based on the dollar amount and the type of orders.

Officials want four pieces of information for each report:

  • The contract number.
  • The total dollar amount invoiced for services performed during the previous fiscal year under the contract.
  • The number of contractor direct labor hours used on the services during the previous year.
  • Data reported by subcontractors, which includes subcontract number and amount of labor hours invoiced by a first-tier subcontractor.

Acquisition regulators are proposing the changes based on the fiscal 2010 Consolidated Appropriations Act. Congress included the reports because of “the absence of complete and reliable information” on the number of contractors doing services work compared to federal employees doing the same.

“Federal agencies are not well equipped to determine whether they have the right balance of contractor and in-house resources to accomplish their missions,” lawmakers wrote in a report accompanying the appropriations law.

The law delves deeply into each services contract to get clearer information that includes:

  • A description of the services and the role the services played in achieving objectives.
  • The agency’s office administering contract and the office using the services.
  • The total dollar amount obligated for the services.
  • The total dollar amount invoiced.
  • The contract type and date of award.
  • The name of the contractor and place of performance.
  • The number and work location of contractor and subcontractor employees.
  • Whether the contract is a personal services contract.
  • Whether the contract was awarded on a noncompetitive basis, regardless of the date of the award.

The information would be added into a new Service Contract Reporting Portal, which is being developed. The information would also be available to the public.

About the Author

Matthew Weigelt is a freelance journalist who writes about acquisition and procurement.

Reader Comments

Thu, May 5, 2011

We have been told to report ONLY 40 hours per week, no matter how many more we work, at the office, at home, from our sick bed, on weekends, on vacation. But work one hour less than 40 and we are branded as unworthy sluggards who just are not "team players".

Thu, May 5, 2011

When I was a contractor 11 years ago I had to fill out a time card with charge numbers, get it signed by the government supervisor (now called the flight chief), then get it signed by an onsite contractor supervisor, then it was sent to the contractor corporate offices and to the Gov. I understand that some of our current contractors have to do weekly reports as well that are sent to the company and to the group they are contracted to.

So does this formalize the actions many of us outside of the DC area have been doing? Make a new set of jobs for his political friends? Looking at the links I see a reference to a page 22070 and other pages in that stratospheric range. No wonder we have so many problems, who can read that much legalese and still be able to work?

Tue, May 3, 2011 Olde Sarge Washington, DC

Most contrators are already providing this information to the agencies through monthly or quarterly program reviews with their supervising COTR. The FAR requires that the data be captured/reported to both the technical managers as well as thrugh the invoice process. This is only an issue if COTRs have not been providing due diligence or agencies have issued myriad contracts or IDIQ tasks that fail to meet the dollar value threshold. Any IG/CFO should see red flags if there seem to be large numbers of small dollar value contracts for services.

Tue, May 3, 2011

Pretty soon there will be no work accomplished on a Government contract, only reporting since that is all they will be able to afford.

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