Government Contracts Proposed DFARS Rule Addresses Collection of Service Contract Data
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Thursday, July 2, 2020

Proposed DFARS Rule Addresses Collection of Service Contract Data

By Government Contracts Editorial Staff

The Department of Defense is proposing to amend the Defense Federal Acquisition Regulation Supplement to change the way it collects service contract data. The rule would implement 10 USC 2330a, as amended by section 812 of the National Defense Authorization Act for FY 2017 (PL 114-328). FAR Subpart 4.17 requires agencies other than DoD to report annually on activities performed by service contractors. This approach uses the Federal Procurement Data System, an existing source of government contract information, to provide a majority of the information required by 10 USC 2330a. The contractor enters data that is not available in FPDS in the System for Award Management. DoD believes that adopting a governmentwide approach to collecting service contract data reduces burden on both industry and DoD, improves data integrity and accuracy, and reforms DoD’s business practices for greater performance. Accordingly, DoD is adopting the approach used by other agencies to collect service contract data.

SAM Reporting. Proposed DFARS Subpart 204.17, Service Contracts Inventory, imposes a requirement to report data annually in SAM when a contractor receives a DoD contract or task order award valued in excess of $3 million that is for logistics management services, equipment related services, knowledge-based services, or electronics and communications services. When applicable, contractors must report the total dollar amount invoiced and the total number of direct labor hours expended on services performed under the contract or task order during the preceding fiscal year. The total number of direct labor hours reported to SAM should be the total of both the contractor’s hours and its subcontractors’ hours. A proposed new clause, DFARS 252.204-70XX, Reporting Requirements for Contracted Services, prescribed at DFARS 212.301, advises contractors of the policy and requirements for reporting data in SAM. This rule replaces the rule in DFARS Case 2012-D051 (¶70,020.346), which proposed to require contractors to annually report service contract data into a DoD-unique database called the Enterprise Contractor Manpower Reporting Application. Comments on the proposed rule referencing DFARS Case 2018-D063 are due August 4, 2020. For the text of the rule, see ¶70,020.452.

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