For better or worse, the age of transparency has arrived. FAR 52.204-10 “Reporting Executive Compensation and First-Tier Subcontract Awards” was promulgated in July, 2010. The clause has been included in most Government contracts awarded since then and is being added to existing GSA schedule contracts. The clause requires prime contractors to report a variety of information regarding their first tier subcontractors and in many cases the compensation of the top 5 executives of the prime and subcontractor.
Starting in December, this information is now being posted on USASpending.gov, the Government’s transparency website. This website is available to the general public to include industry “watch dog” groups, competitors and anybody who may be curious about executive compensation in your company. It remains to be seen whether making this data publicly available has any unforeseen side effects.
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What We Are Writing
- A Marriage of Inconvenience: GSA Schedule Contracts & The Contractor Code of Business Ethics & Conduct Clause
- Emerging Small Businesses: To Grow Your Business, You Must Plan For Growth
- Government Contracting: Look Before You Leap!
- GSA Schedules – Strategies for Success
- New Employee vs. Independent Contractor Considerations
- Pay on Display – Understanding the Executive Compensation and Subcontractor Data Reporting Requirements & Ramifications
- The GSA Schedule: Your Ticket to the Federal Market (May 2010)
- The New FAR Codes of Conduct and Compliance Program Provisions
- The Seven Deadly Sins (of contract compliance)