Jan 5, 2010

Jennifer Aubel

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Resolution #2: We Will Complete Required Contract Reporting Accurately and On-Time

Although we are entering a new calendar year, the emphasis on transparency and accountability that began in 2009 will continue to be a major pressure point for Federal Contractors in the immediate future. Increases to budgets and personnel at oversight agencies will flow down to contractors in the form of increased inquiries and audits. Furthermore, due to the political and economic climate, contractors should expect more scrutiny from legislators, the press and the public, especially in regard to projects funded by the American Recovery and Reinvestment Act (ARRA) and the controversial eVerify system. Penalties for non-reporting can be substantial and can result in consequences up to and including contract cancellation and debarment.

Please follow the link below to see a summary listing of major reporting requirements that may apply to your company. This list is not meant to be comprehensive for all users; please review your contract files to ensure individual compliance.

1. ARRA Reporting: Required quarterly for any contractor who works on a contract that was funded wholly or in-part by the Stimulus Act. Recipient reports are due through FederalReporting.gov on the 10th day after the end of the quarter. As a result of some of the embarrassing problems encountered during that first reporting period, there have been changes made to the system including allowing recipients to edit reports at any time and the creation of a new formula for calculating the number of jobs saved under the ARRA.

2. eVerify: eVerify, a system meant to prevent ineligible employees from working on Federal contracts, became official on September 8, 2009 . FAR Clause 52.222-54, Employment Eligibility Verification, is now included on Federal contracts >$100K and will be incorporated into the GSA Schedules through Mass Modification A059, expected in February, 2010. Generally, contractors will have 30 days from contract award to enroll in eVerify and another 90 days to begin verifying employment status. Less time is allotted if the contractor is already enrolled in eVerify.

3. VETS-100A: Federal contractors with more than $100,000 in annual government contract sales are required to file their VETS-100A reporting annually by September 30th with the Department of Labor. Contractors with sales prior to December 1, 2003 may file using the grandfathered VETS-100 form.

4. EEO-1: Federal contractors with more than 50 employees and more than $50,000 in annual government contract sales are required to file their EEO-1 report with the EEO-1 Joint Reporting Committee annually by September 30th.

5. Affirmative Action Programs: Federal contractors with more than 50 employees and more than $50,000 in annual government contract sales must have developed an Affirmative Action Program (AAP) that includes all offices within 120 days of contract award and maintain a copy on file at corporate office. The AAP must be updated annually. See Title 41, Chapter 60-2 of the Code of Federal Regulations Pertaining to U.S. Department of Labor. The Department of Labor’s Office of Federal Contract Compliance Programs (OFCCP) received a $25M budget increase in FY10 to fund 213 new compliance positions. We expect to see a significant increase in AAP audits in the near future.

6. Subcontract Reporting: Contractors that have Small Business Subcontracting Plans incorporated into any of their contracts are required to report on their progress through the Electronic Subcontract Reporting System (eSRS). Individual Subcontract Reports (ISR) are due semi-annually on April 30th and October 30th. Summary Subcontract Reports (SSR) are due annually on October 30th.

7. 72A Sales Reporting / Industrial Funding Fee (IFF) Remittance: This quarterly sales reporting and fee remittance is specific to GSA Schedule Contract holders and is due on the 30th day after the end of each quarter. Contractors are required to report their sales, even if the total is $0.00. Since GSA is self-funded through the IFF, timely and accurate reporting is crucial to a contractor’s success in GSA’s Contractor Assistance Visits or formal audits.

Ensuring compliance now can help you prevent serious pain in your future. If you have any questions or concerns about your company’s compliance with any of these requirements, please contact Aronson & Company for information at 301-231-6200.