--- title: Subcontractor has to Report Executive Compensation – Say What? description: Do I need to report my executive compensation to the prime? image: https://info.redstonegci.com/hubfs/images/Blog_Images_with_title/RGCI%20-%20Subcontractor%20has%20to%20Report%20Executive%20Compensation%20%E2%80%93%20Say%20What.png --- [ PAY INVOICE](https://redstonegci.com/invoice-payment/) [Call Us Today 256-704-9800](tel:2567049800) [info@redstonegci.com](Mailto:info@redstonegci.com) [![Redstone_Logo](https://info.redstonegci.com/hubfs/redstone%20logo%20version%201%20-%20rgb-1.png)](https://www.redstonegci.com/) # Subcontractor has to Report Executive Compensation – Say What? [Posted by Lynne Nalley, CPA on Tue, Apr 20, 2021 @ 13:04 PM](https://info.redstonegci.com/blog/author/lynne-nalley) - [Tweet](https://twitter.com/share) ![RGCI - Subcontractor has to Report Executive Compensation – Say What](https://info.redstonegci.com/hs-fs/hubfs/images/Blog_Images_with_title/RGCI%20-%20Subcontractor%20has%20to%20Report%20Executive%20Compensation%20%E2%80%93%20Say%20What.png?width=1000&name=RGCI%20-%20Subcontractor%20has%20to%20Report%20Executive%20Compensation%20%E2%80%93%20Say%20What.png) ## What is FAR 52.204-10 – Reporting Executive Compensation and First-Tier Subcontract Awards? FAR 52.204-10 requires the contractor to report executive compensation of first-tier subcontracts with a value of $30,000 unless an exemption applies. Contracting Officers are required to include the FAR clause 52.204-10, Reporting Executive Compensation and First-Tier Subcontract Awards, in all solicitations and contracts of $30,000 or more. A first-tier subcontract is a subcontract awarded directly by the contractor for the purpose of acquiring supplies or services for performance of a prime contract. This does not include long term arrangements between the prime and first-tier subcontractors for material or supplies that benefit multiple contracts. ## What is the Reporting Requirement? FAR 52.204-10 requires prime contractors, as part of its annual registration in the System for Award Management (SAM.gov), to report the names and total compensation of each of the five most highly compensated executives. This requirement is only applicable if the prime’s annual gross revenues from Federal contractors, subcontractors, grants, cooperative agreements in the preceding fiscal year were at least 80% and $25,000,000, and the public does not have access to the information through Security and Exchange Commission (SEC) filings. Prime contractors are to report the five most highly compensated executives for the first-tier subcontractor based on the same criteria; if the subcontractor’s annual gross revenues from Federal contracts, loans, grants, cooperative agreements in the previous year exceed 80% and $25,000,000 and the public does not have access to the compensation information through SEC filings. Prime contractors do not have to report subcontract awards when: - The prime contractor’s gross income in the previous tax year from all sources is under $300,000 or, - The subcontractor’s gross income in previous tax year from all sources is under $300,000. Contracts in which the required reporting would disclose classified information are exempt from the prime and subcontract reporting requirement. If the executive compensation is not reportable because the subcontractor meets an exemption or is already reporting the information, no further action is required by the prime. However, the procurement file of the prime contractor should include documentation detailing the exemption. ## Is there a Time Period of when to Report the Information Into [www.fsrs.gov](http://www.fsrs.gov)? Yes, the prime is required to report the executive compensation along with subcontract/PO information in [www.fsrs.gov](http://www.fsrs.gov) by the end of the month following the month of award of the subcontract. Additionally, the prime is required to report the information annually throughout the performance of the subcontract, if the subcontractor meets the criteria above. ## Anything Else I Should be Aware of? Yes. First-Tier subcontract awards should not be split to a value below the threshold to avoid the reporting requirements under this clause. The FFATA requirement requires all reported information be made public. Prime contractors are responsible for notifying subcontractors that the information will be made public. A best practice would be to document this notification in writing and include it in the procurement file. ## Do I Need a Written Policy? Yes. There should be a written policy documenting the procedure for compensation collection, exemptions, the reporting requirement and time period for reporting in [www.fsrs.gov](http://www.fsrs.gov) and the process for notifying a subcontractor that the data will be public. [Redstone GCI](https://www.redstonegci.com/contact/) assists contractors throughout the [U.S.](https://www.redstonegci.com/u-s-business-consulting/) and [internationally](https://www.redstonegci.com/international-business-consulting/) with understanding the Government’s expectations in reporting Executive Compensation. [![Learn More About Our Contracts & Subcontracts Administration & Support](https://no-cache.hubspot.com/cta/default/203971/interactive-168873885727.png) ](https://info.redstonegci.com/hs/cta/wi/redirect?encryptedPayload=AVxigLIFNcSu%2Byk8l3ibFNS8LnRaTszCd6GFLIQ2OPhQKWq0ux6CIiDcTQyc7iTnyGQFveSQ8ed1cZXB670y9qlvW%2BaxGJEST4RBuOlYhbg1O7YJyXP66p7eBisw4gqZ1SeECB5QoZJ341C0ZMenOmpSj1tvNkNVhwuCQUQaJRduN7oFu2sPZ98nk2aB%2BPJ7JQO7wMDE%2FuPYv34GgVI4RWyA7aGp3VIeHDivtZYdCsIqr%2BIOCPx3RojVzpCfFGK4&webInteractiveContentId=168873885727&portalId=203971) ### Written by [Lynne Nalley, CPA](https://info.redstonegci.com/blog/author/lynne-nalley) ![Lynne Nalley, CPA](https://info.redstonegci.com/hubfs/images/Staff_/Lynne-Nalley.png) Lynne is a Director with Redstone Government Consulting, Inc. providing government contract consulting services to our clients primarily related to Commercial Item Determinations and support, Cost Accounting Standards, DFARS Business System Audits, Proposals, and Incurred Cost. Prior to joining Redstone Government Consulting, Lynne served in several capacities with DCAA and DCMA for over 35 years. Professional Experience Lynne began her career working with DCAA in the Honeywell Resident Office, Clearwater, FL in 1984. Lynne’s experience included various positions which involved conducting or reviewing forward proposals or rate audits, financial capability audits, progress payments, accounting and estimating systems, cost accounting standards, claims and disclosure statement reviews. She is an expert in FAR, DFARS, CAS and testified as an expert witness. Lynne assisted in drafting the commercial item guidance for DCAA Headquarters. Lynne was assigned as a Regional Technical Specialist where she provided guidance to 20 field offices on highly complex or technical issues relative to forward pricing, financial capability or progress payment issues. As an Assistant for Quality, she was involved in reviewing and ensuring audit reports were in compliance with policy and GAGAS as well as made NASBA certified presentations to the staff including but not limited to billing reviews, CAS, unallowable cost and progress payments. To enhance her experience in government contracting, Lynne accepted a position with DCMA in 2015 as part of the newly organized DCMA Cadre of Experts in the Commercial Item Group. This included performing reviews of prime contractor’s assertions and/or commercial item determinations as well as performing price analyses. Lynne was a project lead and later became a lead analyst where she engaged with the buying commands on requests and reviewed price analysis reviews performed by a team of 5 analysts. She also assisted the DCMA CPSR team relative to commercial items and co-instructed the Commercial Item Training presented to DCMA. Education Lynne earned a Bachelor of Science Degree in Accounting from the University of Central Florida. Certifications State of Florida Certified Public Accountant State of Alabama Certified Public Accountant Defense Acquisition Workforce Improvement Act (DAWIA) Level III- Auditing DAWIA Level III – Contracting ## About Redstone GCI Redstone GCI is a consulting firm focused on fulfilling the needs of government contractors in all areas of compliance. With a singular mission to help contractors through the multiple layers of “red tape,” we allow contractors to focus on what they do best – support their mission with the U.S. Government. We are home to a group of consultants made up of GovCon industry professionals, CPAs, attorneys, and retired government audit and acquisition professionals. Our focus and knowledge of audit and compliance functions administered by DCAA and DCMA will always be at the heart of what we do. However, for the past decade, we’ve strategically grown to support other areas of the government contractor back-office with that same level of focus and expertise. We’ve added expertise in contracts management, subcontract administration, proposal pricing, various software systems, HR and employment law, property administration, manufacturing, data analytics/reporting, Grant specialists, M&A, and many other areas. When we see a trend in the needs of contractors, we act to ensure we can provide the best expertise in the market to fulfill those needs. One thing our clients can be certain of is that with the Redstone GCI Team in your corner, there is no problem too big and no issue too technical for our team to tackle. Topics: [DFARS Business Systems](https://info.redstonegci.com/blog/topic/dfars-business-systems), [Contractor Purchasing System Review (CPSR)](https://info.redstonegci.com/blog/topic/contractor-purchasing-system-review-cpsr) ### Search Posts This is a search field with an auto-suggest feature attached. - There are no suggestions because the search field is empty. ### Subscribe via E-mail ### Latest Posts ### Posts by category - [Accounting System Compliance (282)](https://info.redstonegci.com/blog/topic/accounting-system-compliance) - [Commercial Determination (34)](https://info.redstonegci.com/blog/topic/commercial-determination) - [Contractor Purchasing System Review (CPSR) (85)](https://info.redstonegci.com/blog/topic/contractor-purchasing-system-review-cpsr) - [Contracts & Subcontracts Administration (300)](https://info.redstonegci.com/blog/topic/contracts-subcontracts-administration) - [Cost Accounting Standards (CAS) (60)](https://info.redstonegci.com/blog/topic/cost-accounting-standards-cas) - [COVID-19 (23)](https://info.redstonegci.com/blog/topic/covid-19) - [Customer Success Story (2)](https://info.redstonegci.com/blog/topic/customer-success-story) - [Cybersecurity (28)](https://info.redstonegci.com/blog/topic/cybersecurity) - [DCAA Audit Support (249)](https://info.redstonegci.com/blog/topic/dcaa-audit-support) - [Defense Procurement & Acquisition Policy (DPAP) (7)](https://info.redstonegci.com/blog/topic/defense-procurement-acquisition-policy-dpap) - [Deltek Costpoint (54)](https://info.redstonegci.com/blog/topic/deltek-costpoint) - [DFARS Business Systems (179)](https://info.redstonegci.com/blog/topic/dfars-business-systems) - [DOD IG (10)](https://info.redstonegci.com/blog/topic/dod-ig) - [Employee & Contractor Compensation (22)](https://info.redstonegci.com/blog/topic/employee-contractor-compensation) - [Employers & Unions (8)](https://info.redstonegci.com/blog/topic/employers-unions) - [Estimating System Compliance (18)](https://info.redstonegci.com/blog/topic/estimating-system-compliance) - [Export & Import (19)](https://info.redstonegci.com/blog/topic/export-import) - [Federal Acquisition Regulation (FAR) (187)](https://info.redstonegci.com/blog/topic/federal-acquisition-regulation-far) - [Federal Construction Contracting (4)](https://info.redstonegci.com/blog/topic/federal-construction-contracting) - [Government Compliance Training (59)](https://info.redstonegci.com/blog/topic/government-compliance-training) - [Government Property Management (18)](https://info.redstonegci.com/blog/topic/government-property-management) - [Government Regulations (265)](https://info.redstonegci.com/blog/topic/government-regulations) - [Government Shutdown (9)](https://info.redstonegci.com/blog/topic/government-shutdown) - [Grants & Cooperative Agreements (2 CFR 200) (32)](https://info.redstonegci.com/blog/topic/grants-cooperative-agreements-2-cfr-200) - [Human Resources (118)](https://info.redstonegci.com/blog/topic/human-resources) - [Incurred Cost Proposal Submission (ICP/ICE) (83)](https://info.redstonegci.com/blog/topic/incurred-cost-proposal-submission-icp-ice) - [Litigation Consulting Support (17)](https://info.redstonegci.com/blog/topic/litigation-consulting-support) - [Manufacturing Operations Consulting (26)](https://info.redstonegci.com/blog/topic/manufacturing-operations-consulting) - [Material Management & Accounting System (MMAS) (23)](https://info.redstonegci.com/blog/topic/material-management-accounting-system-mmas) - [Non-US Government Contractor (3)](https://info.redstonegci.com/blog/topic/non-us-government-contractor) - [Office of Federal Contract Compliance Programs (31)](https://info.redstonegci.com/blog/topic/office-of-federal-contract-compliance-programs) - [Organizational Change Management Consulting (17)](https://info.redstonegci.com/blog/topic/organizational-change-management-consulting) - [Paycheck Protection Program (PPP) Loans (8)](https://info.redstonegci.com/blog/topic/paycheck-protection-program-ppp-loans) - [Program Management & Project Cost Control (2)](https://info.redstonegci.com/blog/topic/program-management-project-cost-control) - [Proposal Cost Volume Development & Pricing (79)](https://info.redstonegci.com/blog/topic/proposal-cost-volume-development-pricing) - [Quickbooks (21)](https://info.redstonegci.com/blog/topic/quickbooks) - [REAs, Claims & Terminations (10)](https://info.redstonegci.com/blog/topic/reas-claims-terminations) - [Redstone GCI (50)](https://info.redstonegci.com/blog/topic/redstone-gci) - [Sequestration (4)](https://info.redstonegci.com/blog/topic/sequestration) - [Service Contract Act (14)](https://info.redstonegci.com/blog/topic/service-contract-act) - [Small Business Compliance (121)](https://info.redstonegci.com/blog/topic/small-business-compliance) - [System Award Management (SAM) (9)](https://info.redstonegci.com/blog/topic/system-award-management-sam) - [UKG Ready HR Software Consulting (7)](https://info.redstonegci.com/blog/topic/ukg-ready-hr-software-consulting) - [Unanet (35)](https://info.redstonegci.com/blog/topic/unanet) - [Vlog (41)](https://info.redstonegci.com/blog/topic/vlog) ### Disclaimer ``` Data published on our website, such as our white papers, blogs and other government contracting commentary reflect our interpretations and opinions of current events and regulations, at the time such data is published, and the perspectives/opinions of other professionals in our industry may vary from our own.  Further, our commentary and perspectives do not reflect legal analyses, since we are not attorneys, but rather government contracts and accounting advisors.  We therefore make no representation that the use of our published information will insulate a company from government challenges, nor otherwise ensure a successful defense on any government procurement adverse action.  Readers agree that articles or blog commentary presented within our website shall not be replicated or re-published without requesting before publication in another medium, and our expressed written consent to do so. ``` **Redstone Government Consulting** 501 Madison Street SE, Suite 100 Huntsville, AL 35801 **Phone: ** [256.704.9800](tel:2567049800) **Email Us**[ info@redstonegci.com](mailto:info@redstonegci.com) **[PAY INVOICE](https://redstonegci.com/invoice-payment/)** [PCI DSS compliance documentation](https://redstonegci.com/wp-content/uploads/2016/10/pci_dss_self_assessment_certificate.pdf) © 2026 Redstone Government Consulting | All Rights Reserved | [Privacy Policy](https://redstonegci.com/privacy-policy/) | [Event Refund / Cancellation Policy](https://redstonegci.com/event-refund-cancellation-policy/)