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Do the Federal Acquisition Regulation 52.204-11 and June 22 Office of Management and Budget guidance memo have differing requirements?

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Do the Federal Acquisition Regulation 52.204-11 and June 22 Office of Management and Budget guidance memo have differing requirements?

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Yes, they do. Of most importance, (1) For contractors — the Federal Acquisition Regulation limits jobs data to jobs created or retained by the prime Contractor whereas (2) for non-contracts, the June 22 Office of Management and Budget guidance requires Prime Recipient to count jobs by “directly collecting specific data from Sub-Recipient and Vendors on the total Full Time Equivalent resulting from a sub-award.

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