Government Contracts Legal Forum : Government Contracts Lawyers & Attorneys for Litigation & Counseling

On September 20, hundreds of government contractors joined us for a webinar about the new executive compensation and first-tier subcontract award reporting requirements. It was a lively discussion and we explored some of the challenges relating to this new requirement. In case you missed it, the webinar is now available in its entirety by clicking here. Hope you enjoy it.

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Please join us for a webinar on Monday, September 20 at 2 pm ET for a discussion of the new rules requiring many contractors to report information about executive compensation and awards to subcontractors.

During this webinar, we will cover many topics, including:

·        Which companies must report executive compensation information?

·        How is executive compensation calculated?

·        How do these rules apply to publicly traded companies?

·        How does the CCR form work?

·        How should companies collect information from subcontractors?

·        What companies are considered subcontractors?

·        What if a subcontractor refuses to provide the information or the information is subject to a confidentiality agreement?

·        How do companies input the information in FSRS?

·        What will be done with the information?

·        Who will have access to the information?

·        What risks will companies face, even if they comply with this rule?

It should be an interesting discussion, and we hope you can join us.

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We have previously provided information about the interim FAR Rule implementing the Federal Funding Accountability Act of 2006, as amended by the Government Funding Transparency Act of 2008. The Rule, which is already in effect, requires many government contractors to report information about their executives’ compensation, their first-tier subcontractors’ executive compensation, and information about their first-tier subcontract awards. Since the Rule was published on July 8, 2010, government contractors have wrestled with difficult questions of interpretation and implementation issues. 

The comment period closed on September 7, 2010. Comments (pdf.) submitted by the Council of Defense and Space Industry Associations highlight some of the thorniest questions. Issues include:

1) Does the Rule compromise national security because of mandatory disclosure of information about products and services supplied to the US government?

2) Does the Rule cause competitive harm due to disclosure of subcontractor name and pricing information?

3) How should the executive compensation portion of this Rule be applied to publicly traded companies that have hundreds of DUNS numbers and CCR entries?

It will be interesting to see how the FAR Council addresses these - and other - questions that government contractors are raising.

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