Overview
This section outlines the responsibilities of government agencies to monitor and enforce contractor reporting of executive compensation and first-tier subcontract awards via FSRS.gov. It establishes the link between data in the Federal Procurement Data System (FPDS) and contractor reports, while defining the consequences for failing to meet these transparency requirements.
Key Rules
- Agency Monitoring: Agencies must review contractor reports quarterly to ensure consistency with contract information, though they are not required to verify private data they would not normally possess (e.g., specific compensation figures).
- Data Accuracy: Contracting officers are responsible for correcting errors in FPDS, as this data pre-populates contractor reports; contractors must notify the government if they find discrepancies.
- Enforcement: If a contractor fails to comply, the contracting officer must exercise contractual remedies and record the failure in the contractor’s past performance evaluation (FAR subpart 42.15).
- Reporting Exception: Contractors and subcontractors are exempt from these requirements if their gross income from the previous tax year was under $300,000.
- System Limitations: The use of generic entity identifiers interferes with the ability to pre-populate data from FPDS, hindering the reporting process.
Practical Implications
- Contractors should treat reporting as a high-priority compliance item, as failure to report can directly lead to negative past performance ratings and impact future award eligibility.
- Administrative accuracy in the early stages of contract award is critical; contractors must verify that the contracting officer has entered correct data into FPDS to ensure their own reports are prepopulated accurately.