PSC: Eliminate Service Contract Inventory Reporting Requirements

The Federal Acquisition Regulation (FAR) requires federal service contractors to report their direct labor hours and amounts invoiced to the government. This mandate is intended to help federal agencies fulfill their annual requirement to submit to the Office of Management and Budget (OMB) an inventory of activities performed by service contractors, in order to help determine whether agencies have the right balance of contractor and in-house resources to accomplish their missions. However, since contractors are required only to report dollar amounts and the number of full time equivalents (FTEs) employed, agencies lack sufficient context to adequately make such determinations. The government also significantly underestimates the time and cost burden for companies to comply with these requirements—costs ultimately borne by the government.

Based on ineffective outcomes to date and the lack of any perceptible value for the agencies or the public, PSC recommends that Congress repeal the mandate for service contract inventories for both DoD and the civilian agencies and that the FAR Council subsequently repeal the FAR contract clauses at FAR 52.204-14 and FAR 52.204-15. Since detailed information is already reported by the federal government through various other means, the federal agencies are capable of conducting analyses and making total workforce management decisions using already available information. Doing so should results in savings in the millions of dollars and liberate additional contractor and government resources to focus on what matters most–achieving the missions of the federal government and serving the taxpayer.

More detailed information on PSC’s recommendation is included in the attached white paper.

Attachments

- [ Show all ]

PSC-White-Paper---Service-Contract-Inventories---11-09-15-e3acfd.pdf

7 votes

Active

Active

Idea No. 76

Campaign Funnel

Campaign Activity

5 ideas posted
6 comments
30 votes

UndefinedCampaign Owner

Campaigns

All Ideas
Contractors and Grantees
*To participate in the dialogue, you can submit a new idea by clicking "Submit New Idea" to the right, or you can vote and comment on existing ideas below.

Reporting compliance requirements shared by prime and subawardees of Federal procurements and grants
Key Participants: contractors, grantees, cooperative agreement holders, and subawardees
- Question: If you could change one thing that would ease your reporting burden associated with your awards, what would it be (e.g. time, cost, resource, other)?
- Question: If you have reporting requirements to the Federal government, how are those met?
- Question: If you could create a central reporting portal into which you could submit all required reports, what capabilities or functions would you include?
9

3
Contractors
*To participate in the dialogue, you can submit a new idea by clicking "Submit New Idea" to the right, or you can vote and comment on existing ideas below.

Procurement practices, processes, and reporting
Key Participants: Contractors and subcontractors
- Question: If you could change one thing that would ease your reporting burden associated with your awards, what would it be (e.g. time, cost, resource, other)?
- Question: If you have reporting requirements to the Federal government, how are those met?
- Question: If you could create a central reporting portal into which you could submit all required reports, what capabilities or functions would you include?
- Question: Are there any reporting areas in the FAR that are similar in nature to those in Federal agency supplements?
- Question: What other compliance information are you providing to the Federal government outside of the procurement process that could be used in procurement reporting and reduce duplication?
5

6
Grantees
*To participate in the dialogue, you can submit a new idea by clicking "Submit New Idea" to the right, or you can vote and comment on existing ideas below.

Grants practices and processes
Key Participants: grantees, cooperative agreement holders, subgrantees
- Question: If you could change one thing that would ease your reporting burden associated with your grants or subgrants, what would it be (e.g., time, cost, resource burden)?
- Question: If you have reporting requirements to the Federal government, how are those met? (feel free to be specific about what is reported to whom and through what mechanism)
- Question: If you could create a central reporting portal into which you could submit all required reports, what capabilities/functions would you include?
OMB circular A-133:
- Question: If you could make a change to ease your reporting burden for audits under the Single Audit Act (i.e., audits required by OMB Circular A-133 which is being replaced by the Uniform Guidance 2 CFR 200 Subpart F), what one thing would you change about reporting by the auditee?
- Question: If you could make a change to ease your reporting burden for audits under the Single Audit Act (i.e., audits required by OMB Circular A-133 which is being replaced by the Uniform Guidance 2 CFR 200 Subpart F), what one thing would you change about reporting by the auditor?
- Question: If you could make a change to ease your reporting burden for audits under the Single Audit Act (i.e., audits required by OMB Circular A-133 which is being replaced by the Uniform Guidance 2 CFR 200 Subpart F), what one thing would you change about reporting to the Federal Audit Clearinghouse?
Uniform Guidance (2 CFR 200):
- Question: Are there requirements in the new 2 CFR 200 that need additional clarification for improved implementation with reduced administrative burden ?
- Question: What are the perceived burdens associated with the new standards such as the documentation of salaries & wages and time & effort (2 CFR 200.430), subrecipient monitoring (2 CFR 200.331), procurement standards (2 CFR 200.317- 2 CFR 200.324)?
- Question: How can the administrative burden associated with standards compliance be lowered?
51

84

Off Topic

Tags

Voting