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  • Question

    WHEN reporting subcontract awards in esrs should this be done on an annual/fiscal year basis or cumulative over the life of a multi-year contract?


    Answer

    The answer to this question depends on your office policy. FAR 19.704(c) states, “For multiyear contracts or contracts containing options, the cumulative value of the basic contract and all options is considered in determining whether a subcontracting plan is necessary (see 19.705-2(a)). If a plan is necessary and the offeror is submitting an individual contract plan, the plan shall contain all the elements required by paragraph (a) of this section and shall contain separate statements and goals for the basic contract and for each option.”

    Following the contract award,
    FAR 19.705-6(h) requires the contracting officer to acknowledge receipt of or reject the ISR and the SSR in the eSRS. Acknowledging receipt does not mean acceptance or approval of the report. The report shall be rejected if it is not adequately completed, for instance, if there are errors, omissions, or incomplete data. Failure to meet the goals of the subcontracting plan is not a valid reason for rejecting the report.

    The contractor’s reporting requirements in
    FAR 19.704(a)(10) are:
    (iii) Submit the Individual Subcontract Report (ISR), and the Summary Subcontract Report (SSR) using the Electronic Subcontracting Reporting System (eSRS) (http://www.esrs.gov ), following the instructions in the eSRS;
    (A) The ISR shall be submitted semi-annually during contract performance for the periods ending March 31 and September 30. A report is also required for each contract within 30 days of contract completion. Reports are due 30 days after the close of each reporting period, unless otherwise directed by the contracting officer. Reports are required when due, regardless of whether there has been any subcontracting activity since the inception of the contract or the previous reporting period.
    (B) The SSR shall be submitted as follows: For DoD and NASA, the report shall be submitted semi-annually for the six months ending March 31 and the twelve months ending September 30. For civilian agencies, except NASA, it shall be submitted annually for the twelve-month period ending September 30. Reports are due 30 days after the close of each reporting period.

    Since contractors are required to submit their reports in eSRS on a timely basis as stated above, it appears that the contracting officers must acknowledge receipt dependent on the contractor’s submission requirements. You are advised to ask your policy office for further clarification of the reporting requirements in your agency.



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