Comment on FR Doc # 2010-16691

FAC 2005-44, FAR CASE 2008-039 COMMENTS PHYLLIS NICAISE, VICE PRESIDENT CONTRACTS DYNETICS, INC. 256.964.4277 phyllis.nicaise@dynetics.com Reporting of First-Tier Subcontractors’ Executive Compensation Under Supplementary Information, Section C.4, it is stated “The rule requires prime contractors to report first-tier subcontract data on first-tier subcontract awards of $25,000 or more, in http://www.fsrs.gov. The rule also requires contractors to report, at http://www.ccr.gov, the names and total compensation of each of the contractor’s five most highly compensated executives for the contractor’s preceding completed fiscal year in which awards were made, and to make a similar report for subcontractors at http://www.fsrs.gov.” It further states that the rule applies to all businesses (large, small, etc.). All contractors, whether large or small, are required to provide the requested compensation data on the CCR. It is redundant to ask prime contractors to submit data on their first-tier subcontractors which already resides in the CCR. Furthermore, compensation data is considered proprietary to companies. Providing this information or any other type of proprietary data to your prime contractor could jeopardize a contractor’s competitive position. It is not unusual to be a subcontractor to a prime contractor on one effort, and competing with that same contractor on another effort. The Government has typically never asked that proprietary information be provided to prime contractors by their subcontractors, as it is not the Government’s desire to limit competition on any future requirements. Since ALL contractors are required to furnish compensation data on the CCR, the Government should consider eliminating the requirement for the prime contractor to report its subcontractor’s compensation data on http://www.fsrs.gov. Reporting Requested Information Creates Burden Reporting the information cited in 52.210-4(c)(1)(i)-(xiv) will be a tremend