Comment on FR Doc # 2011-09515

The proposed requirement for Contractor's to submit invoiced, annual totals for themselves as well as their first tier subcontractor's may be difficult to implement. The total annual price and the total contract price including remaining options, are both reported on the FPDS-NG. Simple math calculation can be used to divide the totals by the period of performance to determine the annual amounts. I don't see how the breakout down to the subcontractor level would provide much more information, other than to see how much govt funding is trickling down to other subcontractors. I think that the govt is interested in the total $ being expended for all non-govt performed work, whether it is at the prime or subcontractor levels shouldn't matter. The total annual manhours is also something that the CO can easily report on the FPDS-NG, if the field is added. We have that information readily availiable from the contractors' proposals. The CO can report this information for the base award and each option as it is exercised. Again, a little math calculation may be required if the period of performance is more than a year, but the annual hours can be easily determined. In conclusion, our govt contractors have enough on their plates just in performing work for the government and having to jump through all of the reporting hoops that we currently require. Let's not add more burden to them, if we can easily report the information or calculate it from the information that they already provide to the govt.