FAQs

The word “cost” in “Cost and Software Data Reporting (CSDR)" is the key part of this answer. Even though your contract with the United States Government (USG) includes a fixed price for the services performed or products delivered, your internal cost of providing that service or producing that item may vary from the contractual price. As Department of Defense (DoD) cost analysts prepare estimates for the next contract or program similar to yours, this information provides the DoD with the necessary insight to forecast an executable budget in support of the contract or program. Executable budgets, supported with granular cost data and sound analysis, allows the DoD to justify and secure resources within the overarching Federal budget. The CSDR requirement ensures that you, the vendor, will report the actual, internal cost incurred and not simply regurgitate the contract’s Fixed Firm Price.

Neither contract type (e.g., FFP, Cost Plus Fixed Fee (CPFF), etc.), award procedures (e.g., sole-source, full and open competition), nor contract vehicle (e.g., Other Transaction Authority (OTA)) justify a deviation from the requirement for CSDR reporting. 10 USC 3227 (formerly 2334(g)) and DoDI 5000.73 do not differentiate contract type when establishing cost data collection thresholds in statute and DoD policy. 10 USC 3227 states that these CSDR requirements may only be waived by the Director of Cost Assessment and Program Evaluation (DCAPE), DCAPE delegated this waiver authority to the Deputy Director, Cost Assessment (DDCA) in DoDI 5000.73.

Yes. The DoD has successfully collected CSDR data from businesses with non-certified accounting systems. In fact, the DoD’s Cost and Hours Report (FlexFile) CSDR deliverable was developed and implemented primarily in acknowledgement of the substantial differences between contractor accounting systems, CAS or otherwise. The Defense Cost and Reporting Center (DCARC) and DoD cost community will work with your company to align your standard accounting system output to the FlexFile Data Item Description (DID) requirements.

While a CAS may be explicitly required by the FAR for cost type contracts, it is typically not a requirement for FFP contracts. In addition, contracts executed under OTA authority (10 USC 2371b) are not subject to the Federal Acquisition Regulation (FAR) and are unlikely to specify a CAS requirement. As a result, the DoD often awards contracts to small or non-traditional defense contractors without specifying that the contractor must possess a CAS. 10 USC 3227 and DoDI 5000.73 do not accommodate cost data collection exemptions based on CAS considerations. Moreover, DoDI 5000.73 specifies cost data collection requirements for non-FAR contracts (i.e., Other Transaction Agreements). As a result, contracts without CAS requirements that otherwise meet statutory and policy thresholds for cost data reporting must still include an approved CSDR plan and corresponding Contract Data Requirements List (CDRLs).

No. Program Managers, Program Executive Officers, the Senior Contracting Officer, and the Procurement/Agreement Officer are not authorized to waive, omit, or ignore CSDR data collection. This position was fully vetted and endorsed by the Office of the Secretary of Defense’s Office of General Council and Acquisition and Sustainment senior leadership as well as the individual Service Acquisition Executives. Per Section 3227 of Title 10, U.S.C. and DoDI 5000.73, CSDRs may only be waived by the Deputy Director of Cost Assessment and Program Evaluation (DDCA) within the Office of the Secretary of Defense. Removal of CSDR without DDCA approval abrogates statute while placing the program and contract’s future funding resources in jeopardy until CSDR is reinstated or legitimately waived by the DDCA.

Unless the Deputy Director of Cost Assessment and Program Evaluation has waived the requirement, you must provide CSDR data as described in the contract’s CSDR plan. Commerciality – either by part number or for a contract in total – does not disqualify a contract from CSDR reporting. Although commerciality is often considered when reviewing waiver requests, it does not guarantee a waiver will be provided. Only the program manager for your contract can submit a waiver request to CAPE. OSD CAPE considers waiver requests on a case-by-case basis and will render a binding decision for the DoD. The waiver request includes a cover letter on Program Office letterhead with the rationale for the waiver, and a copy of the Commercial Item Determination (CID) signed by a Government contracting officer or by DCMA CID Group. For subcontracts, the waiver request and CID may be signed by the prime contractor’s Principal Contracting Officer.

No. CSDR data and TINA data are not the same thing and requirements for one are unrelated to requirements for the other. TINA data is related to information provided with a proposal, CSDR data is related to data collected during and at the end of contract execution).

Per Section 3227 of Title 10, U.S.C., the DDCA is the only authority that can waive CSDR requirements. The waiver authority for EVM is a separate authority depending on the program. Therefore, waivers for EVM do not waive CSDR requirements. Additionally, the purpose of EVM is a to measure contractors' cost and schedule during contract execution to ensure USG has oversight into the acquisition contract. EVM falls under the purview of the Office of the Undersecretary of Defense for Acquisition and Sustainment (OUSD (A&S)). Whereas CSDR is administered by Office of Cost Assessment and Program Evaluation (OSD CAPE) and is used to capture expenditure, technical, and programmatic data after contract execution. CSDR reporting is the primary data source utilized when completing cost and budget estimates. While OUSD (A&S) officials may have deemed an EVM waiver appropriate, this does not pre-suppose the decision to include or waive CSDR requirements. Although both systems rely on financial information and work breakdown structures, the resulting products from the EVM and CSDR systems are used by different DoD communities, are required at different frequencies, and are used for expressly different purposes.

No. CSDR waivers are granted on a case-by-case basis. Previous waiver decisions may be included as supporting information to the program manager’s waiver request to the DDCA; however, the DDCA reserves the right to not to grant a waiver request for a similar contract in the future, based on changes in conditions.

Yes. The DoD cost community recognizes economic optimization drives contractor purchasing and production decisions. We are looking to collect CSDR data from weapon system contracts, not create CSDR data contracts that also produce weapon systems. In most cases, we’ve found that contractors execute purchase and/or work orders at a much smaller quantity than lot/option totals. In some cases, this quantity might be 1, but it’s more often the case that the quantity is some fraction of the overall quantity required by the delivery order or contract option. Providing direct labor and/or material at this lower “sub-lot” level is acceptable and even a desirable alternative to forcing serial number/vehicle level reporting, to the degree that the data matches your company’s production approach for the item being manufactured. Bottom line: USG wants data that resembles your company’s process for batching or grouping smaller quantities as it works toward meeting the overall quantity requirement. Although simply reporting/rolling up data to the whole contract lot/delivery order/task order level is not an acceptable alternative to “unit-level” reporting, providing data at the “sub-lot” level likely is. Contractors should identify their proposed “sub-lot” reporting at or before the CSDR Readiness Review (previously Post Award Conference). If your CSDR plan indicates unit/sublot reporting, ensure your system is set up in advance to accommodate the reporting requirement.

No. The DDCA will separately consider CSDR waivers for qualifying subcontractors, irrespective of the decision rendered on a prime contractor’s waiver request. Requests for waivers for all contracts and subcontracts will be considered on a case-by-case basis.

All CSDR plans are tailored to the contractor's accounting system(s) and technical approach to accomplish the contractor's scope of work requirements, irrespective of the size of the contractor, experience with CSDR, or the type of contract (e.g., FAR, MTA). The review of the CSDR plan's requirement and potential tailoring occur at the CSDR Readiness Review. The CSDR Readiness Review should happen as early in the acquisition process as is practical and allowed by the contracting officer (preferably before contract award) in order to ensure accounting systems and the like are prepared to collect data as required.

The CSDR process requires CWIPTs prepare initial CSDR plans before solicitations are released and before the CSDR Readiness Review can be held, therefore, initial CSDR plans in solicitations are unlikely to be tailored to a contract's accounting system(s) or technical approach to contract execution. CWIPTs prepare these initial CSDR plans to include the data collection requirements they believe are necessary to ensure CSDR deliverables will contain data needed to complete estimates & analysis and ensure DoD decision makers can make data-informed decisions. During the CSDR Readiness Review, the CWIPT and contractor may identify CSDR requirement modifications in order to tailor reporting to the contractor's accounting system and technical approach, thereby increasing the quality of data collected. Which requirements may be tailored cannot be known before the CSDR Readiness Review or before the CWIPT understands gains an understanding of the contractor's systems and processes.

The goal of CSDR is to collect quality cost data and enable DoD to make data-driven decisions while not causing an undue burden to contractors, their accounting system(s), processes, or technical approach to execution. However, all contracts include minimally acceptable terms and conditions which must be met; the collection and reporting of CSDR is one such requirement. Generally, if a contractor can pay their employees, send and receive invoices from supplies, and pay taxes, they have an accounting system and processes mature enough to be compliant to CSDR requirements.

If the Cost Working Integrated Product Team (CWIPT) decided to retain a WBS element without any scope under the contract, report $0 for that element if no funds were expended towards it. It’s likely due to a desire for uniformity or consistency between contracts and programs in the DoD’s CSDR database. In many cases, these elements, which may seem superfluous to your contract, are included to ensure the plan remains compliant with the current version of MIL-STD-881. In other cases, the superfluous elements might be included for consistency with previous contracts for the same item or an antecedent system. By keeping these elements, analysts are able to observe a “meaningful” zero, as the $0 cost submission is accompanied by a remark indicating no scope in the CSDR WBS dictionary entry. This outcome is preferred to an ambiguous lack of reporting against an otherwise standard cost element.

No. The term “optional” on page 5 refers to the ability of the USG CWIPT to exercise discretion in adding the associated requirements. By exercising the option to include, say, unit-level reporting on the CSDR plan, the CWIPT has introduced unit-level reporting as a contractual requirement via the approved CSDR plan.

Approval of submission date changes is within the purview of the program office and DCARC. The CWIPT will want to understand your desired submission event dates and how they align with your accounting calendar, equipment delivery dates and contract close out dates; changes to these dates are based on programmatic and schedule changes. Requests for submission date extensions submitted after the due date are not permitted.

CSDR data is marked and protected as “contractor proprietary” data and meets DoD IL-5 classification as “Controlled Unclassified Information.” The data is tightly controlled, with only access granted to individuals that meet a rigorous vetting process to ensure control of the data, nor is it releasable under FOIA requests. CSDR data is encrypted both in transit and at rest and stored within the CADE database. In addition, there is a recurring process to ensure the CADE system retains its protection of contractor data. During these reviews CADE is often quoted as having the “platinum standard” for data integrity.

Your subs will be treated as “Direct Reporting Subcontractors” for the purposes of this contract, and are required to submit directly to CADE, not the Prime Contractor. You, the prime contractor, will not receive the subcontractor’s data deliverables. Your subs will have the opportunity to conduct separate CSDR Readiness Reviews (formerly Post Award Conferences) with the CWIPT, and most importantly, they will submit all CSDR deliverables directly to OSD’s CADE database (not to you, the prime contractor).

The current reporting requirements are designated in DoDI 5000.73 and essentially follow a two-part process. First, the CWIPT determines if the total acquisition program funding is greater than $100M. This is regardless of the program acquisition pathway. If the acquisition program funding is greater than $100M and any of the contract reporting thresholds for CSDR requirements are met in Table 1, then CSDR requirements should be levied.