DoD Service Contract Reporting FAQs 29 October 2020.pdf

DoD Service Contract Reporting FAQs

SERVICE CONTRACT REPORTING POLICY

SERVICE CONTRACT REPORTING USER ROLES

CONTRACTOR SAM REPORTING

DOD AGENCY ACTIONS

SERVICE CONTRACT REPORTING POLICY

Question: Why is DoD no longer using ECMRA?

Answer: DoD has elected to adopt the approach used by other Federal agencies to collect service contract data. The approach uses the Federal Procurement Data System (FPDS), an existing source of contract information for the Federal Government, to provide a majority of the information required by 10 U.S.C. 2330a. The data that is not available in FPDS is entered annually by the contractor in the System for Award Management (SAM). Adopting a Governmentwide approach to collecting service contract data reduces burden on both industry and DoD, improves data integrity and accuracy, and reforms DoD's business practices for greater performance and affordability. For more information, please see:

https://www.federalregister.gov/documents/2020/06/05/2020-11754/defense-federal-acquisition-regulation-supplement-data-collection-and-inventory-for-services.

Question: I’m a COR or Contracting Officer, what is my role regarding Service Contract Reporting?

Answer: Per FAR 4.1703(b), agencies are required to review submitted reports for reasonableness and consistency; and inform the contractor if they believe changes are warranted.

Reporting on all service contracts/Task Orders (TOs) is mandatory to support the annual SECDEF manpower report to Congress.

Question: How does SAM generate the actions for which Service Contract Reports are required?

Answer: SAM obtains contract data for certain covered contracts from FPDS based on applicable Service Contract Reporting thresholds in FAR Subpart 4.1703, with exceptions as noted in statute for DoD. For entities registered in SAM with DUNS Numbers/UEI Numbers containing applicable contracts, a "Service Contract Reporting (SCR)" link under "Entity Registrations" is available in SAM during the annual reporting period.

SERVICE CONTRACT REPORTING USER ROLES

Question: What are the Contractor (Non-Government) Roles in service contract reporting

(SCR)?

Answer:

• Prime Contractor: The role of a Prime Contractor within SCR is to add or edit contract data. A prime contractor can only access contract information for a contract for which they are associated to.

• Sub-Contractor: The role of a subcontractor within SCR is to add or edit contract data.

Question: What roles in SAM will the Contractor (Non-Government) need for SCR?

Answer: In SAM, the Contractor will need to register as one of the following:

• Entity Registration Viewer

• Entity Registration Representative

• Services Contract Inventory (SCI) Reporter

• Entity Administrator

Question: What are the Government Roles in service contract reporting (SCR)?

Answer:

• CORs: The role of a COR, within SCR, is to review for reasonableness and consistency.

Contracting Officers should advise the contractor to make changes if they appear warranted.

• Contracting Officer: The role of a Contracting Officer, within SCR is to review for reasonableness and consistency. Contracting Officers should advise the contractor to make changes if they appear warranted.

Question: What roles in SAM will the Government user need for SCR?

Answer: No special SAM government roles are required for searching and viewing contractor Service Contract Reports. SAM Government users with For Official Use Only (FOUO) access can view the SCRs as reported by a Contractor. You must be logged into SAM with your individual SAM user account tied to your U.S. government email address to search for and view SCR information.

Question: I’m a Government User who is a COR or CO. What role do I need to apply for to see SCR information for a contractor?

Answer: CO/CORs are no longer required to enter any contract information in order for the vendor to report. All contract data is sourced from FPDS. As a COR or CO, you will not be required to obtain a special SAM role to review reported SCR information, you will just need to log into SAM to view SCR data. Specific SAM roles are only needed for vendors.

CONTRACTOR SAM REPORTING

Question: I’m a Contractor and I cannot find my contracts/orders in SAM. Why did they not migrate/transfer into SAM from FPDS-NG for SCR?

Answer: Recent legislation has limited the number of DoD contracts affected by the manpower reporting requirement. This may be a reason why some previously reported contracts are no longer eligible for FY20 reporting.

Please double check the SCR criteria in the SCR Guidebook to confirm the award is in excess of $3M and meets PSC requirements, which have narrowed. If you find the award is eligible, check that the data elements in the contract action report (CAR) are correct and do not contain errors that may have prevented the award data to flow from FPDS to SAM. The Business Rules for FPDS sourced data to SAM is located in the DoD Procurement Toolbox.

If you find an award/order should have an SCR after validating the PIID, total contract value, and PSC code matches the executed award document and CAR please reach out to your Contracting Officer who can submit an FSD ticket.

Please review the PSCs (and other criteria) closely for applicability. The Business Rules for FPDS sourced data to SAM is located in the DoD Procurement Toolbox along with the other referenced documents.

Question: Can I manually add award data into SAM for Service Contract Reporting?

Answer: No, there is no functionality in SAM to manually add award data to SAM. Please see the below criteria for reporting. Note that FY20 SCR submissions are extended through January 31, 2020 per the DoD memo dated October 16, 2020:

Policy Vault:

https://www.acq.osd.mil/dpap/ops/policy_vault.html

Memorandum:

https://www.acq.osd.mil/dpap/policy/policyvault/USA002161-20-DPC.pdf

Question: Where is ECMRA?

Answer: ECMRA was de-commissioned as of June 19th, 2020 and the data collection functionality has transitioned to the System for Award Management (https://sam.gov).

Contractors need to wait until the service contracting reporting period opens in SAM to take action on your FY20 service contracts.

Question: What is the responsibility of the contractor?

Answer: With regards to contract reporting, the role of the Contractor within SAM is to add or edit contract data. A Contractor can only access contract information for a contract for which they are associated to and a contractor will need a SAM user account to perform reporting.

Specifically, contractors will:

I. Submit or edit a SCR by adding the service contract which meets the FAR Subpart

4.1703 reporting thresholds

II. Add the following information:

o Total Amount Invoiced o Prime Contractor Hours Expended

III. Report any required Tier 1 subcontractor information IV. Submit the report

Question: I’m new to SAM Contract Reporting. Where can I find instructions?

Answer: GSA has created a “Quick Start Guide” that will provide details on how to get started with contract reporting. To access the guide, follow these steps:

§ Go to www.sam.gov § Click on “HELP” section § To find the SCR Quick Start Guide o Click on “User Guides” on the left menu o Click on “Quick User Guide” o Under “Quick Start Guide for Service Contract Reporting (SCR)”, click on

“Download PDF”

Question: I’m a DoD Contractor, when can I start reporting on my service contracts for 2020 in SAM?

Answer: Service Contract Reporting opens for DoD on October 16, 2020 at 5:00pm EST.

Question: When does service contract reporting end?

Answer: The reporting period has been extended to Jan 31, 2021 for submission and correction of reports. Please view the DoD memo dated October 16, 2020 located here:

https://www.acq.osd.mil/dpap/policy/policyvault/USA002161-20-DPC.pdf.

Question: I’m a DoD Contractor, how do I know if I need to report my contract in SAM?

Answer: Review the threshold criteria for when Contractors are required to submit a SCR.

Detailed descriptions of Reporting Thresholds are available in the Service Contract Reporting Guidebook located in the Procurement Toolbox: https://dodprocurementtoolbox.com/site-pages/service-contract-reporting-sci.

The DoD awarded contracts that meet or exceed threshold requirements for reporting will be available in SAM to report against during the open period.

Question: I’m a Contractor and forgot to submit my service contract report in SAM, what should I do?

Answer: You need to reach out to your Contracting Officer. If the contractor fails to submit the report in a timely manner, the contracting officer will exercise appropriate contractual remedies.

In addition, the Contracting Officer will make the contractor’s failure to comply with the reporting requirements a part of the Contractor’s performance information under FAR subpart 42.15.

Question: How can a Contractor check to see if they have contracts subject to the SCR requirements?

Answer: In SAM:

1. Log in to www.sam.gov

2. Select “Register/Update Entity”

3. Click “Service Contract Report”

If you are a service contractor and do not see a “Service Contract Reporting (SCR)” link, then you either do not have reporting privileges (are not an Entity Administrator, Entity Registration Representative or Reporter). For more detailed steps, please see the Quick Start Guide by following these steps:

§ Go to www.sam.gov § Click on “HELP” section § To find the SCR Quick Start Guide o Click on “User Guides” on the left menu o Click on “Quick User Guide” o Under “Quick Start Guide for Service Contract Reporting (SCR)”, click on

“Download PDF”

Question: I’m a Contractor and in SAM, but do not see the “Service Contract Reporting (SCR)” link or any contracts listed for reporting?

Answer: If you are a Service Contractor and do not see a “Service Contract Reporting (SCR)” link, then you either do not have reporting privileges (are not an Entity Administrator, Entity Registration Representative or SCI Reporter) or you do not have contracts subject to the SCR requirements (FPDS has not identified any contracts/orders subject to the SCR requirement for FY2014). However, if you believe you have a contract subject to SCR which is not listed, contact your contracting officer and verify the information has been loaded into FPDS.

Question: What information do I need to provide in the Service Contract Reports?

Answer: Users are required to input and submit the following SCR data elements:

• Total dollar amount invoiced for services performed under the contract in the preceding government fiscal year

• The number of prime contractor direct labor hours expended under this contract

• If applicable, Tier 1 Subcontract number, including DUNS number/ UEI and name.

- Number of subcontractor direct labor hours expended under the contract.

Please contact your contracting officer with questions on how to identify the resources to answer the questions on the Service Contract Reports.

Question: Will my Contracting Officer be able to comment on my Service Contract Reports?

Answer: There is no functionality for the Contracting Officer to comment on your Service Contract Reports. The contracting officer can only view your Service Contract Reports. If they have any questions or concerns about the information you submitted, they need to contact you directly. You may edit the information entered until the reporting deadline.

Question: How do I submit the data for Full Time Equivalent (FTE) Employees?

Answer: SAM automatically converts the prime contractor direct labor hours expended into a full time equivalent (FTE) employee value based on one (1) FTE equaling 2,080 hours.

SAM divides the direct labor hours expended by 2,080. For example, if you enter 6,240 hours for Prime Contractor Hours Expended field, SAM would calculate a Full Time Equivalent (FTE) employee value of three.

Total FTEs is the sum of the calculated prime contractor FTEs and any calculated subcontractor FTEs. The system adds these values together when you submit the report. The field will remain blank until then.

Question: Will SAM notify my Contracting Officer that I submitted my Service Contract Reports?

Answer: SAM will not notify your Contracting Officer that you submitted your Service Contract Reports. Please contact your Contracting Officer after you submit your Service Contract Reports in SAM so they may review them.

Question: What is the 'Upload Service Contract Report File' link that is under the 'Entity Registrations' link?

Answer: You have an additional option for reporting service contract information. If you are an entity with multiple contracts enabled for SCR, you may want to consider using the ‘Upload Service Contract Report File’ link. Instead of completing and submitting one SCR at a time, you now have the ability to complete and submit multiple SCRs at once in an XML file.

Question: Can I make changes to the Service Contract Reports after I submit them?

Answer: Yes. Service Contract Reports will remain editable until January 31st of the following year for which reporting is required.

Question: Where can I find a schedule for SCR in SAM?

Answer: The Federal Schedule for FY2020 for Contractor Service Reporting in SAM can be found in Attachment 1 in the “Deploying Contractor Service Contract Reporting in the System for Award Management (SAM)” Memorandum located in the Procurement Toolbox:

https://dodprocurementtoolbox.com/site-pages/service-contract-reporting-sci.

Question: The Federal Service Desk told me my contracts may not show in SAM because of a 90 day delay. Is this true?

Answer: GSA did not apply a 90-day delay. If your contracts are not showing in SAM, it most likely is because the contract is below the $3M threshold and not a covered PSC. Some services and agencies continue to require manpower reporting above and beyond what the statute requires based on the 2011 policy letter rescinded in Oct 2019.

Question: I’m a Contractor and my SCR contains errors. How can I get the errors fixed?

Answer: If you notice errors in the data prefilled from FPDS, contact your government Contracting Officer to correct it. While the SCR section of SAM will be available for reporting and corrections until January 31, 2021, DoD contractors must complete reporting per the terms of their contracts.

Question: I’m a Contractor and I need more SAM help, where can I find more directions?

Answer: There are detailed steps on Service Contract Report and how to access, create, edit and delete reports in the SAM User’s Guide. To access Help, follow these steps:

§ Go to www.sam.gov § Click on “HELP” section § To find the SCR Quick Start Guide o Click on “User Guides” on the left menu o Click on “Quick User Guide” o Under “Quick Start Guide for Service Contract Reporting (SCR)”, click on

“Download PDF” § Find the Full SAM User’s Guide o Click on “User Guides” on the left menu o Click on “Full User’s Guide” o Under “Non Federal User Guide”, click viewing preference - “Download PDF” or

“View Online”

Question: I’m a DoD Contractor and have questions regarding contract reporting in SAM that are not answered in the FAQs, who do I contact?

Answer: The centrally-managed Federal Service Desk (FSD) is a great resource for free help with the System for Award Management (SAM). You can search the knowledge base for an answer to your question or start a live chat, submit a web form, or call to open a service ticket.

o Contact the FSD directly at: www.fsd.gov / U.S. calls: 866-606-8220 / International calls: +1 334-206-7828 / DSN: 94-866-606-8220).

o They are well-equipped to handle your questions.

§ Be sure to provide as much detail as you can.

§ Ensure you promptly respond to any follow-up questions from the agent.

§ Tickets will be closed in 3 days if you fail to respond.

DOD AGENCY ACTIONS

Question: I’m a COR or Contracting Officer and my Contractors have submitted their service contract reports. What actions do I take?

Answer: Agencies will review Contractor reported information for reasonableness and consistency. In the event the agency believes that revisions to the contractor reported information are warranted, the agency shall notify the contractor and the contractor shall revise the report.

SAM closes for FY 2020 contractor reporting on January 31, 2021.

Question: How do I know if a Contractor needs to report in SAM?

Answer: The award meets or exceeds the SCR threshold criteria. Eligible contracts shall include the applicable Service Contract Reporting Requirements clause. DoD contracts may include the clause if they include any civilian agency funding.

Question: I’m a COR or CO, can I manually edit or upload contracts to SAM for reporting?

Answer: No, there is no ability to manually edit (upload) contracts to SAM for reporting. The data pull from FPDS is very complex, using the stated criteria for SCR eligibility. Go to the FY2020 Service Contract Reporting Rules posted to the DoD Procurement Toolbox https://dodprocurementtoolbox.com/site-pages/service-contract-reporting-sci to view the business rules.

If, after review of the fiscal year SCR Business Rules and review of FPDS, you believe that there was an actual mistake in the data pull, you should submit an FSD ticket "Service Contract Reporting". This will get routed to an appropriate SME for review.

Question: I’m a COR on a task order and my CO has already verified the service contract.

Do I also need to verify?

Answer: Yes, for CORs under task order (TO) contracts, the Contracting Officer may have already verified your TO, but CORs still need to go into SAM and verify the contract/TO. CORs are ultimately responsible for ensuring the information is correct. Please check with your CO to verify if they are in agreement.

Question: I’m a DoD Agency user of ECMRA, but now need to access Service Contract Reports in SAM. Do I need access to SAM?

Answer: Yes, you will need a SAM user account that is associated to a government email address. On the SAM homepage located at sam.gov, click “Login” in the top right corner. That will bring you to a Login.gov page where you can click on “Create Account”. Step by step directions, with pictures on creating an account can be found here:

https://login.gov/help/creating-an-account/how-to-create-an-account/.

For more information on the types of SAM roles you can request, the “Quick Start Guide for Federal Employees” can be found by following these steps:

§ Go to www.sam.gov § Click on “HELP” section § To find the Quick Start Guide o Click on “User Guides” on the left menu o Click on “Quick User Guide” o Under “Quick Start Guide for Federal Employees”, click on “Download PDF”

Question: I’m a DoD Agency SAM User, how do I view Service Contract Reports?

Answer: SAM users with For Official Use Only (FOUO) access can view the Service Contract Report(s) as reported by an entity (Contractor). Users who have FOUO access in SAM include:

• Users who have been granted FOUO Entity Management Data User (or higher sensitivity) access

• Users who have an account with a U.S. Federal Government role

• Users who have created an account with a U.S. Federal Government email address

To view Service Contract Reports, follow these steps:

1. Log into SAM.gov

2. Select the “Search Records” tab from the SAM main navigation bar and search for the entity by its Legal Business Name, DUNS, or CAGE

3. On the “Search Results” page, select “View Details” for the entity

4. Under the “Reports” section on the left side of the page, select “Service Contract Report”

Question: As a CO or COR, will I be able to comment on the Service Contract Reports in

SAM?

Answer: SAM does not have functionality for you to be able to comment on your contractor’s Service Contract Reports. You can only view the Service Contract Reports in SAM. You must provide any comments or feedback to the contractor directly.

Question: I’m a Government user looking at a Contractor’s SCR and there are errors.

How can I get the errors fixed?

Answer: You will need to contact the Contractor to advise them to correct the submitted report.

If you see errors in the data that was pre-populated from FPDS, please contact the government Contracting Officer to correct their contract action report in FPDS.

Question: Is the threshold for SCR reporting by Contractors being changed to just contracts >$3M across the board to align with what is reported in the ICS, or will it continue to be broken down by category as it is at FAR 4.1703?

Answer: DoD is exempt from the reporting thresholds in 4.1703. In the interim, refer to the Guidebook/business rules for criteria, available in the DoD Procurement Toolbox. Guidebook updates to thresholds were made to add more clarification/simplify information.

Recent legislation has limited the number of DoD contracts affected by the manpower reporting requirement. This may be a reason why some previously reported contracts may no longer be eligible for reporting. Please review the PSCs (and other criteria) closely for applicability.

Question: I’m a Contracting Officer and wondering if there is interim instruction or language to put in contracts whether by modification for existing contracts, and/or for new ones awarded between now and the time we have a final DFARS clause?

Answer: Eligible contracts are not exempt from Service Contract Reporting and the CAR data (that populates SAM) continued to be collected during this period. Even though ECMRA decommissioned in June, there was no impact to SCR data collection/report submission since the open reporting period is mid-October to mid-December.

Question: When does service contract reporting end?

Answer: The reporting period has been extended to Jan 31, 2021 for submission and correction of reports. Please view the DoD memo dated October 16, 2020 located here:

https://www.acq.osd.mil/dpap/policy/policyvault/USA002161-20-DPC.pdf.

Question: Will the reporting parameters and criteria remain the same from FY20 throughout the life of the contract? I am asking since FY 20 is stated in the guidance, I am wondering if we will receive updated guidance for FY 21 and if that guidance could possibly have different parameters.

Answer: The reporting thresholds and applicable PSCs (derived from former portfolio groups and cross-walked to current categories) is established in law at 10 U.S.C. 2330a. That will be spelled out in the future DFARS rule. So, when the law changes, likely will need to issue a deviation and amend the DFARS, but do see that on the horizon anytime soon.

Question: How do I track SCR reporting progress?

Answer: Guidance is taken from the GSA’s SAM User Guide. If you don’t have the SAM permissions, please go to your agency SAM admin to obtain ability to perform the requested action.

12.8 Service Contract Reports

Those users with FOUO access can also download the summary Service Contract report to track reporting progress. This .xls document contains all covered Service Contract Reports from FPDS for that fiscal year. This file can be found in the Entity Management (EM) Extracts section under Data Access. The following users can access the file:

· Users who have been granted FOUO Entity Management Data User (or higher sensitivity) access

· Users who have an account with a U.S. Federal Government role

· Users who have created an account with a U.S. Federal Government email address

You must be logged into SAM to download the file.

NOTE: An interim version of the file is posted bi-weekly during the reporting period. A final summary of Service Contract Reporting activity for the fiscal year is posted after the reporting period has closed.

Question: The COR’s Designation Letter in JAM reflects ECMRA and not SAM. What should we do?

Answer: The JAM team is aware and an update to the Designation Letter is in the backlog for updating. Continue to mark the field in the Designation Letter.

Question: I’m with a DoD Agency and I still need more help, where can I find more directions?

Answer: There are detailed steps on Service Contract Report and how to access, create, edit and delete reports in the SAM User’s Guide. To access Help, follow these steps:

§ Go to www.sam.gov § Click on “HELP” section § To find the SCR Quick Start Guide o Click on “User Guides” on the left menu o Click on “Quick User Guide” o Under “Quick Start Guide for Service Contract Reporting (SCR)”, click on

“Download PDF” § Find the Full SAM User’s Guide o Click on “User Guides” on the left menu o Click on “Full User’s Guide” o Under “Federal User Guide”, click viewing preference - “Download PDF” or

“View Online”

Question: I’m with a DoD Agency and have questions regarding contract reporting in SAM that are not answered in the FAQs, who do I contact?

Answer: The centrally-managed Federal Service Desk (FSD) is a great resource for free help with the System for Award Management (SAM). You can search the knowledge base for an answer to your question or start a live chat, submit a web form, or call to open a service ticket.

o Contact the FSD directly at: www.fsd.gov / U.S. calls: 866-606-8220 / International calls: +1 334-206-7828 / DSN: 94-866-606-8220).

o They are well-equipped to handle your questions.

§ Be sure to provide as much detail as you can.

§ Ensure you promptly respond to any follow-up questions from the agent.

§ Tickets will be closed in 3 days if you fail to respond.

The Service Contract Reporting Guidebook and Memorandum are located in the Procurement Toolbox: https://dodprocurementtoolbox.com/site-pages/service-contract-reporting-sci.

You may contact Jessica Williams at jessica.m.williams126.civ@mail.mil or Dana Chan at dana.c.adler@us.ibm.com for assistance with SAM itself. Contact Jeff Grover at jeffrey.c.grover.civ@mail.mil for policy questions regarding service contract reporting requirements.