If you feel overwhelmed by government reports, the following information will shed light on three of the more common contract requirements, including 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) business receives a contract that is more than $700,000 (except for construction in which case 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), this report is due semi-annually for the periods October 1 to March 31 and October 1 to September 30. The reports are due 30 days after the reporting period ends, April 30 and October 30, respectively.

The data provide 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 Sam.gov if they have (1) 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 FY16 and subsequent years ($1 million if awarded in FY15 and $2.5 million if awarded in FY14). 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 provide 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 report is required for contracts involving services, including contracts for supplies with services at a Department of Defense (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 do not include direct labor hours and dollars. The report is due no later than October 31 for the preceding fiscal year.

This report helps the government capture the DoD workforce composition and allows for informed workforce staffing decisions, oversight, and accountability.

Consider these reporting requirements carefully. Reporting on a timely basis can enhance your relationship with the contracting officer. Conversely, failing to report can negatively affect your CPARS rating.

If you have questions, contact us today at 703-218-3600 or click here. To review our government contracting articles, click here. To learn more about MCB’s government contracting practice and our experts, click here.


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