Comment on FR Doc # 2011-09515

Item 3 of the new reporting requirements states that: "(3) The number of contractor direct labor hours expended on the services performed during the previous fiscal year." Currently, on firm-fixed price, project-based work the government and contractor negotiates the price of performance-based deliverables rather than level of effort or labor hours. Subsequently, contractors track and manage firm-fixed price projects differently than they do time and material contracts. Therefore, I believe that this requirement is contradictory to the intent of Performance-Based and/or Firm-Fixed price contracts and task orders. This element of the report would effectively require contractors to track and report the activities of the contract execution on a labor-hour basis. If the government is going to require that contractors track and report direct labor hours expended on firm-fixed price projects, then it is likely that the project should be a labor hour contract rather than a firm-fixed price contract. Which for many contractors, shifting the risk associated with fixed-price projects back to the government would be appealing.