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    Our CFO just asked me what the CFSR requirements are for subcontractor reporting. I know there are conditions under which subs must submit CSDR info but I can’t speak to the CFSR requirement at the subcontractor level. Can you provide any guidance or reference sources I can look to for this question?


    Answer

    :  This response is based on the information provided.  We suggest you discuss with your contracting team, program manager and/or legal department as appropriate.

     

    We do not have the details of your contract, but offer the following.  The Government generally does not have privity of contract, i.e., a contractual relationship with the subcontractor.  As such the Government would not routinely receive this information.  You are able to negotiate flow-down of the requirement from the prime to the sub (at a cost).  To justify doing so, the subcontract would have to be a significant portion of the overall contract cost and of a high dollar amount on a contract running a year or more.

     

    As the CFSR provides to the PM from the contractor includes:

    Updating and forecasting contract funds requirements; Planning and decision making on funding changes in contracts Developing funds requirements and budget estimates in support of approved programs Determining funds in excess of contract needs available for deobligation Obtaining rough estimates of termination costs Determining if sufficient funds are available by fiscal year to execute the contract It is not something subcontractors would submit since the prime reports on subs in the Open Commitments and Accrued Expenditure sections. Additionally, the CFSR requires data in fields the subcontractor is probably not privy to, i.e., appropriation code, contract number, etc.

     

    You should reread DID DI-MGMT-81468 for additional information.   The contracting officer and contractor should negotiate reporting provisions in the contract, including level of detail and reporting frequency.

     

    To determine what you are able to do now, you need to read your contract, particularly the related FAR part 32 clauses and your related CDRL items.

     

     

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