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DoN Contract Management Reporting Application (CMRA). For the Old Dominion Chapter of the National Contract Management Association. By Denise L. Randolph January 16, 2013. CMRA Statute Summarized.
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DoN Contract Management Reporting Application (CMRA) For the Old Dominion Chapter of the National Contract Management Association By Denise L. Randolph January 16, 2013
CMRA Statute Summarized United States Code title 10, Section 2330a requires an annual inventory of contracted services including the number and cost of FTEs
Overview of Statutory Requirements • Description of the services purchased • Description of the function and mission performed • Identification of Personal Service Contracts • Identification of the fiscal year when the activity first appeared in the section 2330a inventory
Overview of Statutory Requirements, con’t • Contracting organization • Type of contracting action • Identification of non-DoD contracting agencies • Funding source (appropriation type and operating agency) • Identification whether contracts were performance-based contracts
Overview of Statutory Requirements, con’t • Extent of competition and identification of awards with more than one bid • Identification of Small Business, Disadvantaged and Women-owned contractors • Total invoiced amount • Number of contractor employees, expressed as FTEs using direct labor hours and associated cost data collected from contractors1 1 Section 2330a mentions that the number of contractor employees and associated cost data is to be collected from contractors, except that estimates may be used where such data is not available and cannot reasonably be made available
Overview of DoD Full Year Appropriations Act 2011 Section 8108 • 8108 (a) • Not less than $2M shall be made available for leveraging the Army’s CMRA • Army CMRA to be modified, as appropriate, for documenting the number of full-time contractor employees pursuant to United States Code title 10, section 2330a
Overview of DoD Full Year Appropriations Act 2011 Section 8108 • 8108 (c) • Secretaries of the Army, Navy, Air Force, and the Directors of the Defense Agencies and Field Activities, in coordination with the Under Secretary of Defense for Personnel and Readiness, shall report to the congressional defense committees within 60 days of enactment of this Act their plan for documenting the number of full-time contractor employees as required by United States Code title 10, section 2330a
CMRA System Features • Web-based data collection tool for collecting contractor and sub-contractor direct labor hour, direct labor cost, direct non-labor costs, invoiced amount, location where work performed • Secure, accredited web application with sign-in and security protocols with different access for different users • Contractor verification through CAGE code • Bulk data-loader function for loading data from EXCEL spreadsheets
CMRA System Features, con’t • Collects contact information for contractor and COR/KO • Search capability on pre-loaded contract data • Fund cite pre-loaded from Army Contract Business Information System • Data integrity look-up feature (e.g., UIC, Product Service Code) • Controlled sub-contractor data entry role
CMRA System Features, con’t • Edit features with controlled time-stamp and user identity • Data validation with controlled range parameters for direct labor hours and costs • Relational SQL Server data base consisting of entities: contract/task order/fund cite/location • Standard Reports
CMRA Business Processes • Reporting requirement included in NMCARS (not yet a standard FAR clause) • Paperwork Reduction Act approval from OMB (includes Cost Benefit Analysis and Fed. Reg. Notice/Comment) • Includes fixed price contracts by treating direct labor hours/costs as proprietary when specifically linked to contractor name and contract/task order number • Minimal reporting burden recovered through overhead
CMRA Business Processes, con’t • Annual reporting for prior fiscal year • Specific and clear guidance on definition of invoiced amount and reporting period for performance within fiscal year • Convert direct labor hours to FTE by dividing with 2,088 • Demo and Users Manual at https://doncmra.nmci.navy.mil
Implementation in DON • NMCARS SUBPART 5237.1—SERVICE CONTRACTS GENERAL • 5237.102 Policy (90) DoD contracting activities awarding or administering contracts shall incorporate the following Enterprise-wideContractor Manpower Reporting Application (ECMRA) standard language into all contracts which include services, provided the organization that is receiving or benefiting from the contracted service is a Department of Defense organization, including reimbursable appropriated funding sources from non-DoD executive agencies where the Defense Component requiring activity is the executive agent for the function performed. The reporting requirement does not apply to situations where a Defense Component is merely a contracting agent for another executive agency. The only contracted services excluded from reporting are construction and utilities. The standard language to be inserted is:
Implementation in DON, con’t “The contractor shall report ALL contractor labor hours (including subcontractor labor hours) required for performance of services provided under this contract for the [NAMED COMPONENT] via a secure data collection site. The contractor is required to completely fill in all required data fields using the following web address https://doncmra.nmci.navy.mil . Reporting inputs will be for the labor executed during the period of performance during each Government fiscal year (FY), which runs October 1 through September 30. While inputs may be reported any time during the FY, all data shall be reported no later than October 31 of each calendar year. Contractors may direct questions to the help desk, linked at https://doncmra.nmci.navy.mil.”
CMRA going forward • eCMRA is moving to DISA in conformance with policy directives for hosting applications • governance body being solicited, designated to collect funding, to control the configuration, and oversee operating and moving eCMRA instances to DISA • New site address MAY be http://www.ecmra.mil • 1st meeting will be tomorrow (1/17/13)
What’s going on? • Working to Reissue NMCARS • Reviewing/Validating Component Clauses • Service Acquisition Workshops • Limitation on Amounts Available for Contract Services (Section 808) • Accelerated Payments to Small Businesses • Do Not Pay Legislation • Elimination on Cap on Women-owned Small Businesses
CONTACT INFORMATION: DENISE L. RANDOLPH Senior Procurement Analyst Office of the Assistant Secretary of the Navy (Research, Development & Acquisition) Deputy Assistant Secretary of the Navy (Acquisition & Procurement) Office Email: Denise.Randolph@navy.mil Office Phone: (703) 614-9767 Personal Email: DeniseRandolph@yahoo.com