Based on the lack of any perceptible value for the agencies or the public, we recommend that Congress repeal the mandate for reporting on executive compensation and that the FAR Council subsequently revise the relevant contract clauses. Doing so will save 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 ...more »
The FAR requires semi-annual submission of Individual Subcontract Reports (ISRs) for all federal agencies, as well as Summary Subcontract Reports (SSRs) for DoD and NASA, and annual submission of SSRs for civilian agencies. In addition to the submissions required during performance of a covered contract, ISRs are required to be submitted within 30 days of contract completion. Amending the FAR, at a minimum, and the ...more »
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 ...more »
Harmonize Requirements and Standardized Collection of Non-Financial Training Prior to Issuance of an Award - Non-Financial Investigator training requirements (e.g. Financial Conflict of Interest, Responsible Conduct of Research, Research with Human Subjects), are convoluted because acceptable subject matter and timelines for completion vary by agency. Non-financial training requirements should be harmonized to reduce ...more »
Change UG to Allow 120 Days for all Final Reporting (Financial and Programmatic) for all agencies Currently the Uniform Guidance (UG) requires that all financial & programmatic reports are submitted to the sponsor within 90 days after end date. Several agencies, through coordination with the FDP (Federal Demonstration Partnership) and COGR, are adjusting their deadlines to 120 days after end-date. These agencies, most ...more »
Since the publication of the Uniform Guidance UG), institutions have seen various Conflict of Interest (COI) terms and conditions embedded within broad agency announcements and proposal solicitations, despite the lack of formal agency-wide policies or guidelines in most cases. The specific requirements for what financial interests and relationships need to be disclosed, the nature and timing of reviews, and even definitions ...more »
Last year, the Coalition for Government Procurement submitted a number of recommendations in response to the Chief Acquisition Officers Council (CAO) Council Open Dialogue to improve the economy and efficiency of the Federal acquisition system. The Coalition urges the government to take action on the previously submitted recommendations to increase the efficiency and the effectiveness of Federal procurement. Implementing ...more »
Suggestions on how the benefits of the Performance Measures could be enhanced and the burdens of reporting could be reduced.