C. Thresholds

Comment: A number of respondents requested that the threshold for including the clause in contracts be increased. One respondent recommended that this clause only apply to sole source contracts over $1 million and competitively awarded contracts over $50 million. Another respondent thought that the Government could report 80 percent of all contract activity by selecting only 20 percent of the largest contracts. A respondent recommended that the Government conduct another pilot program to assess the true cost to report contracts at $25,000, and above to assess the true extent to which reporting such low dollar value subcontracts is useful to the public in reducing wasteful and unnecessary spending.

Response: The Transparency Act requires the full disclosure of all Federal award information for awards of $25,000 or more.

Comment: A respondent wanted to see all the applicability details laid out in a concise flow chart so that all contractors can easily decipher the rule.

Response: The applicability of FAR 52.204-10, Reporting Executive Compensation and First-Tier Subcontract Awards, is clear on its face. Also, additional information is available at https://www.fsrs.gov/, which provides responses to frequently asked questions, a user guide, and gives an explanation of FSRS.

Comment: A respondent thought that the rule does not provide sufficient guidance concerning its applicability to indefinite-delivery indefinite-quantity (IDIQ) contracts, and that the rule should be revised to state that the thresholds are to be applied at the order level.

Response: The applicability section of the interim rule published in the Federal Register on July 8, 2010, at 75 FR 39414, required that contracting officers modify existing IDIQ contracts on a bilateral basis in accordance with FAR 1.108(d)(3) to include the clause for future orders. This includes modifying blanket purchase agreements under IDIQ contracts. IDIQ contracts include Federal Supply Schedule contracts and task and delivery-order contracts such as Governmentwide acquisition contracts.