52.204-10 Reporting Requirements and SAM
Started by _KB_ · Nov 17, 2022 · 3 replies
- _Original post
_KB_
Nov 17, 2022 · 3y ago
My company has two prime contracts: One is a CPFF TO under a IDIQ vehicle and the other is a CPAF single award contract. Neither of these contracts include 52.204-10 Reporting Executive Compensation and First-Tier Subcontract Awards. Both do, however, include 52.204-13 System for Award Management Maintenance, and one of the reps and certs within SAM is 52.204-10. Based on this, I have two questions:
- Since 52.204-13 is included, we do have to complete the certification for 52.204-10 in SAM. BUT, since 52.204-10 is not included as a contract clause, my firm does not have to complete any reporting in FSRS, correct? I want to ensure we are not negligent on any reporting requirements.
- What are possible reasons why the contracts don't include this clause? Looking at the clause and 4.1403(a), it seems like they should be included.
Thanks!
- j
joel hoffman
Nov 17, 2022 · 3y ago
Not sure of the reason you are asking here rather than ask the KO. If the answer is yes do the report, you will be reimbursed, right?
- _
_KB_
Nov 17, 2022 · 3y ago
We are not concerned with the costs or time associated with doing the reporting, more-so with understanding the requirement and if it is applicable or not. Since it is not in the contract, it appears obviously inapplicable, but I was seeking insight from this group on why it may not have been included in the awards, and if this is common.
I like to understand the "why" behind things, and speaking with colleagues and other contracting professionals has always proved more fruitful than asking KOs.
- N
Neil Roberts
Nov 18, 2022 · 3y ago
_KB_ said:
I was seeking insight from this group on why it may not have been included in the awards,
FAR 4.1403(b) might be a reason why.