As of April 4, 2022, the federal government will stop using the Dun & Bradstreet (D&B) Data Universal Number Systems (DUNS) Number to uniquely identify entities and will fully transition to using the Unique Entity Identifier (UEI). All entities will be using the UEI number for SAM and other government systems (including FPDS.gov, eSRS.gov,
Reporting and Disclosure
DoD Requests Public Input on Sustainability and Climate-Related Disclosures




On July 8, 2021, DoD published a request for information (RFI) soliciting the input of interested parties on sustainability initiatives and climate-related disclosures. DoD’s request asks companies to comment on their voluntary efforts in measuring and disclosing Greenhouse Gas (GHG) Emissions, Environment, Social, and Governance (ESG) reporting, and Supply Chain GHG and Risk Management, but could be a prelude to a mandatory disclosure scheme for defense contractors.
ESG and other disclosures pertaining to sustainability and climate are growing in importance for a wide range of companies, as investors, stakeholders, and customers increasingly are interested in and evaluating progress on sustainability-related disclosures and the business practices and plans underlying them. Companies are now under more pressure to demonstrate forward movement on ESG and other sustainability metrics, particularly in the areas of climate change, environmental justice, industrial chemical use, diversity and inclusion, and compliance and ethical business practices.
Over the last several years, more and more companies have voluntary published sustainability reports. However, there is an evident lack of standardization in these disclosures, and companies vary greatly in what they measure and disclose. Without a standardized ESG disclosure framework, investors, consumers, stakeholders and the government may be unable to reasonably evaluate and compare companies’ ESG practices and risks.…
Continue Reading DoD Requests Public Input on Sustainability and Climate-Related Disclosures
Contractors Can Review and Object to Public Release of Information in FAPIIS

On January 3, 2012, the FAR Council issued a final rule to implement a congressional mandate that the public have access to all information (excluding past performance reviews) in the Federal Awardee Performance and Integrity Information System ("FAPIIS"). FAPIIS was created in 2010 as a one-stop shop for contracting officers to review information about contractors’…
Department of Defense Proposes Expanded Property Reporting Rule
On October 19, 2011, the Department of Defense (“DoD”) proposed a new rule to amend DFARS § 252.211-7007 to remove the $5000 threshold from reporting requirements for Government-furnished property. The proposed rule would require contractors to report Government-furnished property to the DoD Item Unique Identification (“IUID”) registry regardless of value. DoD states that the intent…
Draft Executive Order Requiring Broad Contractor Disclosure of Political Contributions Faces Strong Opposition from Industry and Congressional Republicans

On April 13, 2011, the Obama administration released a draft executive order called “Disclosure of Political Spending by Government Contractors.” This executive order, if implemented, would instruct the FAR Councils to amend the FAR to require significant disclosures about contractor political contributions to be made as part of any proposal submitted by a firm seeking …
Public Access To FAPIIS

As we blogged previously, as of today – April 15, 2011 – the public has access to all information (excluding past performance reviews) in the Federal Awardee Performance and Integrity Information System (“FAPIIS”). FAPIIS was created in 2010 as a one-stop shop for contracting officers to review information about prospective contractors’ business ethics, integrity, …
Beware: Government to Release Private Contractor Information Contained In FAPIIS

On January 24, 2011, the FAR Council issued an interim rule to implement a congressional mandate that the public must have access to all information (excluding past performance reviews) in the Federal Awardee Performance and Integrity Information System ("FAPIIS"). FAPIIS was created in 2010 as a one-stop shop for contracting officers to review information about…
In Case You Missed Our FFATA Webinar

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…
New Reporting Requirements For Recipients Of Grants and Other Forms of Federal Financial Assistance

On September 14, 2010, OMB issued two regulations implementing the Federal Funding Accountability and Transparency Act of 2006 requirements applicable to recipients of federal financial assistance. The first (pdf.) requires (among other things) that for any new award made after October 1, 2010, applicants and recipients of grants and cooperative agreements must register in the …
Webinar about Reporting of Executive Compensation And Subcontract Awards
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?
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