Tag Archives: compliance

GSA Contemplates Making Transactional Data Reporting Pilot Participation Optional

At a recent industry event, Kevin Youel Page, the deputy commissioner of GSA’s Federal Acquisition Service (FAS), made a surprising revelation – GSA is considering making participation in its controversial Transactional Data Reporting (TDR) pilot program completely optional. Currently, only existing contractors can choose whether they want to participate, and even they have to participate if they add a Special Item Number (SIN) to their contract or renew it. Mandatory participation also applies to all new offers against Schedules included the pilot.

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Hawaii General Excise Tax and the Unsuspecting Government Contractor

Winning a contract in a new state can present many challenges, not least of which is ensuring that your company is compliant with the state’s tax code. The worst approach to state tax compliance is assuming that the taxes your company may be subject to and the tax treatment of your company’s activity will be the same as in other states. This is especially the case when it comes to Hawaii. It’s not surprising that many government contractors venturing into Hawaii overlook the General Excise Tax (GET), as it’s often assumed that the GET is essentially the same as most other states’ sales and use taxes. However, the unique nature of the GET can catch many businesses off guard, and the Department of Taxation’s penalties can be quite unforgiving.

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Roadmap to DFARS Compliance Deadline

2017 is a significant year for Department of Defense (DoD) contractors, as Defense Federal Acquisition Regulation Supplement (DFARS) compliance is required “as soon as practical, but no later than December 31, 2017 (252.204-7012.ii.A).” DFARS clause 252.204-7008 addresses requirements for safeguarding covered defense information controls in government contractor systems. Covered defense information is a broad term for unclassified controlled technical information or other Controlled Unclassified Information (CUI), which has protection and dissemination requirements. Clause 252.204-7012 expands on these safeguards to include cyber incident reporting requirements. These mandatory controls are detailed in the National Institute of Standards and Technology (NIST) Special Publication (SP) 800-171: Protecting Controlled Unclassified Information in Non-Federal Information Systems and Organizations.

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Additional Small Business Subcontracting Plan Compliance Requirements Underway

Significant regulatory changes instituting small business subcontracting improvements have been incorporated into the Federal Acquisition Regulations (FAR), imposing additional small business-related obligations on large prime contractors (“Prime”). Although these changes went into effect on November 1, 2016, businesses may not experience their full impact until later this year. Existing government systems, such as the Electronic Subcontracting Reporting System (eSRS), need to be modified to accommodate several of these compliance requirements.

The GSA has started incorporating the updated FAR clauses containing these provisions into its Schedule solicitations via refreshes and mandatory modifications. The most significant changes being implemented are as follows:

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Upcoming GSA and Federal Contract Reporting Deadline Reminder!

Federal contractors, don’t forget that three important reporting deadlines are coming up this month! For GSA Schedule contract holders, the deadline for 72A Sales Reporting and IFF remittance is Sunday, October 30th. You must report, even if you have zero sales in the preceding quarter.  Log in to the 72A Reporting website to complete these action items.

For contractors who have an approved small business subcontracting plan on an active federal contract, the Individual Summary Report (ISR) and/or Summary Subcontracting Report (SSR) must also be submitted by Sunday, October 30th.  Reports are required regardless of whether there has been any subcontracting activity.  Log into the eSRS system to complete your ISR and/or SSR.

Finally, companies with service contracts containing FAR 52.204-14 or 52.204-15 (which includes GSA Schedule holders), must complete their Service Contract Report (SCR) in the System for Award Management (SAM) by Monday, October 31st. You can find more detailed information about the SCR requirements, including submission instructions, in this blog.

A failure to meet service contract reporting requirements may result in the government finding a contractor non-compliant.  In accordance with FAR Subpart 4.1704,“If the contractor fails to submit a report in a timely manner, the contracting officer shall exercise appropriate contractual remedies…[and] make the contractor’s failure to comply with the reporting requirements a part of the contractor’s performance information” in the Contractor Performance Assessment Reporting System (CPARS).

Should you have any questions or concerns regarding these reporting requirements or deadlines, please contact Jennifer Aubel at jaubel@aronsonllc.com 301.231.6253.


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