Service Contract Reporting Requirements for Indefinite-Delivery Contracts
Contractors with indefinite-delivery service contracts must annually report detailed labor and cost data—including subcontractor information—via SAM.gov, or risk contractual penalties and negative performance evaluations.
Overview
FAR 52.204-15 establishes annual service contract reporting requirements for contractors holding indefinite-delivery contracts. The clause mandates that contractors report specific data about services performed under qualifying orders, including information about first-tier subcontractors, to the government via the System for Award Management (SAM) website. The goal is to increase transparency and oversight of service contract labor and expenditures.
Key Rules
- Annual Reporting Requirement
- Contractors must report annually by October 31 for services performed in the previous government fiscal year for orders exceeding the threshold in FAR 4.1703(a)(2).
- Required Data Elements
- Reports must include contract/order numbers, total invoiced amount, direct labor hours, and relevant subcontractor data.
- Submission Method
- All required information must be submitted electronically via www.sam.gov.
- Agency Review and Revision
- Agencies review submissions for accuracy and may request revisions by November 15; contractors must respond by November 30.
- Subcontractor Reporting
- Contractors must collect and report specified data from first-tier subcontractors with qualifying subcontracts and inform them that the data will be public.
Responsibilities
- Contracting Officers: Monitor compliance, enforce remedies for late/missing reports, and incorporate reporting performance into contractor evaluations.
- Contractors: Collect, compile, and submit all required data on time; coordinate with first-tier subcontractors; revise reports if requested.
- Agencies: Review submissions for accuracy, request corrections, and ensure public transparency.
Practical Implications
- This clause ensures government visibility into labor and costs associated with service contracts and subcontracts.
- Contractors must establish robust data collection and reporting processes, especially for tracking labor hours and coordinating with subcontractors.
- Failure to comply can negatively impact contractor performance ratings and may result in contractual remedies.