Tuesday, November 4, 2014

Some Contractors are Contractually Required to Furnish Organization Charts

There is an active FAR case requesting public comments on whether a current data collection requirement should be continued. These kinds of requests pop up all the time. Requests for data from contractors must be approved by the OMB (Office of Management and Budget) and these approvals have sunset clauses, meaning that they will expire unless re-approved by OMB. This request involves the submission of an organization chart for contractors with cost-type construction contracts.

Many times we wonder about the genesis of these data requests. Who wanted them? Why was it considered necessary? Why was it so necessary and important that it had to be included in the procurement regulations? Why wouldn't the contractor provide an organization chart without a clause requiring them to do so? And then we wonder whether anyone cares anymore. Who collects the data? What do they do with it? Is there a compliance officer out there somewhere checking to see if the contractor complies? What happens if the contractor does not comply? Would anyone notice? And on and on.

The current request is the requirement in FAR 52.236-19 which states:
When this contract is executed, the Contractor shall submit to the Contracting Officer a chart showing the general executive and administrative organization, the personnel to be employed in connection with the work under this contract, and their respective duties. The Contractor shall keep the data furnished current by supplementing it as additional information becomes available.
 The FAR councils estimate that this requirement will apply to 50 contractors annually and it will take 45 minutes to comply for a total of 38 hours. We dare say that the Government has already expended significantly more than 38 hours just publishing this silly request, not to mention the other incremental cost related to this action.

Money well spent.

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