OMB is required to establish a free public website containing full disclosure of all Federal contract award information. The public may view first-tier subcontract award data at http://usaspending.gov.

Contractors must now report executive compensation and first-tier subcontract awards on contracts and orders expected to be $25,000 or more (including all options), except classified contracts and contracts with individuals.

Reporting requirements are phased as follows:
1. Until September 30, 2010, any newly awarded subcontract
must be reported if the prime contract award amount was
$20,000,000 or more.
2. From October 1, 2010, until February 28, 2011, any newly
awarded subcontract must be reported if the prime contract award
amount was $550,000 or more.
3. Starting March 1, 2011, any newly awarded subcontract
must be reported if the prime contract award amount was $25,000
or more.

FAR 4.1400 requires the total compensation of the five most highly compensated executives of contractors and first-tier subcontractors to be reported by name and total compensation. There are certain exceptions which are detailed in the new FAR provisions, and certain definitions such as “compensation” are essential to fully understanding the new requirements.

For more information about the new requirements contact government contracts attorney Karen S. Hindson of Hindson & Melton LLC.