Accurate and Complete Subcontract Data Needed To Assess International Agreements on Defense Procurement
NSIAD-85-30
Published: Dec 13, 1984. Publicly Released: Dec 13, 1984.
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Highlights
In response to a congressional request, GAO reported on improvements needed in the Department of Defense's (DOD) subcontract-level reporting system, a data collection system which requires prime contractors and subcontractors to report foreign-source purchases valued at more than $10,000.
Recommendations
Recommendations for Executive Action
| Agency Affected | Recommendation | Status |
|---|---|---|
| Department of Defense | The Secretary of Defense should make available the required personnel to maintain and operate the subcontract-level reporting system consistent with DOD overall staffing needs and priorities. |
Closed – Implemented
DOD assigned this responsibility to one staff person as a collateral duty. This individual initiated action on implementing two of the remaining recommendations and automated the data collection and analysis process.
|
| Department of Defense | The Secretary of Defense should revise the DOD supplement to the Federal Acquisition Regulation (FAR) and, when necessary, Form DD-2139 to institute a method for assessing compliance with the subcontract-level reporting system, such as a negative reporting requirement. |
Closed – Implemented
DOD will not initiate a study to assess compliance until after completion of changes to the DOD FAR supplement. Staff intend to compare firms reporting under the subcontract system with those shown to have large contracts under the DD-350 system. Where a firm receiving a large contract has not reported under the subcontract system, DOD will contact it regarding the reporting requirements.
|
| Department of Defense | The Secretary of Defense should revise the DOD supplement to FAR and, when necessary, Form DD-2139 to require that the subcontract-level reporting system use country of origin rather than principal place of performance to indicate foreign-source procurements. |
Closed – Implemented
DOD revised the reporting regulations and the form to reflect this recommendation. The new form and regulations would require prime contractors to use country-of-origin to indicate foreign-source procurements.
|
| Department of Defense | The Secretary of Defense should revise the DOD supplement to FAR and, when necessary, Form DD-2139 to require that contractors receiving contracts for commercial items report on subcontracts meeting the value threshold for reporting, except procurements of ores, natural gas, utilities, petroleum products and crudes, timber, and subsistence items. |
Closed – Implemented
DOD has revised the reporting regulations and the form to reflect this recommendation. The new form and regulations would require prime contractors receiving contracts for commercial items to report on subcontracts meeting the threshold.
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Topics
Data integrityDefense agreementsDefense procurementForeign trade agreementsForeign trade policiesInternational tradePersonnel managementReporting requirementsSubcontractorsInternational organizations