If you are new to the government contracting world here is a subject you might not be familiar with – Contract Data Requirements List (CDRLs). You might think contract data requirements would be easy; but, like most of government contracting, it can be very complicated. CDRLs are used to call out deliverables on a contract. Failure to submit the CDRLs can result in the government withholding payment or asking for consideration for late delivery. So, when bidding an RFP, make sure you study the CDRLs required and account for the preparation time needed to submit these documents over the life of the contract, if your company wins.
Usually CDRLs are used for two reasons. The first is to delivery important data like studies, analyses or other data that the contractor is tasked with producing, even software. The other reason is to delivery administrative data such as cost funds status reports, progress reports or whatever the government wants to know about the contract.
The CDRL itself is comprised of either a single DD Form 1423 or a series of DD Forms 1423 containing data requirements and delivery information. As with any government form, it has many blocks that describe what the CDRL title is, how often it is to be delivered and format information. Attached should be a sheet describing each block to help you understand the form. Agencies have the ability to tailor the look and information in each CDRL, so no two may look alike.
I am not going to go through each block but Block 4 “AUTHORITY (Data Acquisition Document No.) “is very important. Contained in this block should be a Data Item Description (DID) which will describe the format of how the data is to be delivered. Of course, since it’s a government form, it contains a form number that you need to look up. To look up any DID you need to go to: http://quicksearch.dla.mil/qsSearch.aspx
Quick Search Assist should have a .pdf version of the DID so you can see the format requirements and in many cases what data needs to be on the deliverable.
Another important block is 10 “Frequency”. How often you have to deliver a CDRL is important. If you are on a cost contract the agency may require an expenditure report to be delivered every month. Other data may be required to be delivered once at the end of the contract. How often administrative data is required to be delivered and proper format needs to be understood to perform the contract correctly.
Getting to know the CDRLs is not something you wait to do after you win the contract! It is something you need to understand and include in your proposal cost. Even a service contract may have CDRLs for the simplest services. I have had discussions over formats, frequency, content and even the occasional “we can’t track that” – after award, which is not a good thing.
I have seen problems on cost contracts, where expenditure data CDRLs were not delivered to the customer and there was a big surprise when the contractor called one day and said “Hey I am running out of money”. Or the data was delivered and no one in the government looked it over and the government folks are surprised when they get the “Hey I am running out of money” call. The CO Is not the manager of the work so it falls upon the government customers to track that data. However, if you are having problems and reporting them through a CDRL, also reach out to CO and let him know. That way he can warn the government customer to look at that data.
Failure to deliver CDRLs can and should result in withholds on contract payment. Some CDRLs for DoD contracts, may require a DD250 if acceptance is done by the Defense Contract Management Agency (DCMA). Failure to complete or deliver data is a non-performance issue and subject to withholds until completed.
Data management is not easy, as most contractors and government personnel want to focus on the product or service. However, the CDRLs are there for a reason and a good CO will look to make sure that contractor delivers them and that the government personnel look over the management data being provided. The CDRL is a good tool to document progress and have a record of expenditures.
Shelley Hall note: Under most commercial contracts (and even some non-commercial ones) many government agencies are getting rid of CDRLs and simply stating the deliverables in the PWS or SOW. This makes the process so much clearer than using the antiquated CDRLs.