Small Business Liaison Officer Training

Small Business Participation and
Administration of Subcontracting Plans
Stephanie Lewis
Small Business Administration
Office of Govt. Contracting

Small Business Participation
Federal Contracts > Simplified Acq. Threshold
($150,000)
FAR 52.219-8 Utilization of Small Business Concerns
Applies to Large and Small prime contractors
“Maximum practical utilization”of small business concerns as
subcontractors
Federal Contracts > $650,000 (or $1.5 million for
construction)
FAR 52.219-9 Small Business Subcontracting Plan
Applies only to Large businesses.

Subcontracting plans are not required
(FAR 19.702)...
From small business concerns
For personal services contracts
For contracts performed exclusively outside the United
States
When there will be no subcontracting whatsoever
Self-performing entire contract and no materials purchased
.

Subcontracting Plan in Contract Award
Failure to submit and negotiate the subcontracting plan shall
make the offeror ineligible for award of a contract
FAR 52.219-9(c)
Subcontracting plan should be negotiated before award
FAR 19.705-2(d) and -4(b) and (c)
Becomes a part of the contract award document

Content of Subcontracting Plans
State goals for SB, SDB, WOSB, HUBZone SB, VOSB, and SD-
VOSB
Contain both dollar and percentage goals
Establish base and option year goals separately
Fully explain what items will be subcontracted and from what
size business
Explain good faith efforts going to put forth to involve small
businesses in each size category
Agree to flow down the subcontracting plan requirement in
subcontracts over the threshold
A contract can only have one subcontracting plan

Good Faith Efforts
Break apart orders into feasible units
Conduct market research to identify small business
subcontractors and suppliers through all reasonable means:
search on the Central Contractor Registration/Dynamic Small
Business Search
Post notices of Sources Sought and/or Requests for Proposal on
SBA’s SUB-Net
Participate in Business Matchmaking events and attending prebid
conferences;

Good Faith Efforts
Solicit small business concerns as early in the acquisition process as
practicable to allow them sufficient time to submit a timely offer for
the subcontract
Provide interested small businesses with adequate and timely
information about the plans, specifications, and requirements for
performance to assist them in submitting a timely offer
Negotiate in good faith with interested small businesses
Direct small businesses that need additional assistance to SBA
Utilize the available services of small business associations, and local
small business assistance offices, and other organizations
Participate in a formal mentor-protégé program with one or more
small-business protégés that results in developmental assistance to the
protégés.

Who Approves the Subcontracting
Plan?

Subcontracting Plan Approval
Offeror sends it to the Contracting Officer
Contracting Officers route each plan to the agency’s
Small Business Specialist and the SBA Procurement
Center Representative (PCR) for comments
Check for realistic goals and required elements of the
plan.

Types of Subcontracting Plans

Four Types of Subcontracting Plans
1. Individual Subcontracting Plan
Contains all the required elements of a subcontracting plan, including
goals, for one federal contract. Remains the same for the life of the
contract (unless it is modified and approved by the Contracting Officer).
2. Master Plan
Appropriate for companies that submit lots of plans.
Boiler plate: contains all the required subcontracting plan elements except
for goals and the rationale used to develop goals.
Goals and rationale are developed on a contract by contract basis.
Good for a three year period

3. Commercial Subcontracting Plan
Preferred type for offers supplying a Commercial Item to the Govt.
Applies to production of both commercial and non-commercial products rather
than solely for one Government Contract.
Annual plan based on the contractor’s fiscal year
Can be company-wide or division-wide, plant-wide, or based on product line
Approved by the agency awarding the first federal prime contract
Subsequently approved by the Contracting Officer with the contract that has the
furthest completion date

4. DoD Comprehensive Test Subcontracting
Program (Comp Plan)
Subcontracting plan set forth annually that covers all DoD
subcontracting for the govt. fiscal year
Negotiated annually with DCMA
Two target SDB categories
Non DOD contracts must still have Individual/Commercial
Plan
Comp Plan participants:
www.acq.osd.mil/osbp/programs/csp/index.htm

Subcontracting Plan
Reporting - www.esrs.gov

Reporting Requirements: Individual
Subcontracting Reports (ISRs)
For Individual Subcontracting Plans (Not required for
Comprehensive or Commercial Plans)
Due semiannually -- for the periods ending March 31 and September
30, and at contract completion
Used to determine if subcontracting plan goals are being
met.
Report goals from subcontracting plan and subcontracts
placed since inception of the contract.

ISR Entry Preparation (prime)
Agency must have entered your prime contract into
FPDS
As a prime contractor you will need:
Your DUNS number used to bid on the contract
Product/Service Code (describes what is being purchased)
Contract NAICS code
The prime contract number
Current contact value
A copy of your approved subcontracting plan
Email address of the federal government agency responsible
for reviewing your report

ISR Entry Preparation (sub)
As a subcontractor to a higher tier prime contractor, you will
need:
The prime contract number
The subcontract number
The DUNS number of the contractor that awarded you the
subcontract
Product/Service Code required by the subcontract
Subcontract NAICS code
A copy of your approved subcontracting plan
Email address of the individual responsible at the higher tier
contractor responsible for reviewing your report

ISR Entry Steps
Enter prime contract number
Indicate if you are a prime contractor or subcontractor

ISR Entry
Based on the prime contract number, the system is going to
populate several fields:
DUNS
Contractor’s Name Address
Agency Awarding the contract
Product/Service Code & NAICS Code
Current Contract Value
Ultimate Contract Value
Any errors must be corrected by the Contracting Officer in
FPDS

ISR Entry: reporting period

Enter goals and achievements to
date

Reporting Requirements: Summary
Subcontract Report (SSR)
For Individual/Master/Comprehensive Plans:
Due semiannually for DoD and NASA contractors
Due annually for civilian contractors, except NASA
for the periods ending March 31 and September 30.
For Commercial Plans
Due Annually for the period ending September 30

SSR entry in eSRS
Format similar to ISR input
No goals – just input subcontracts awarded during reporting
period
Submitted on a corporate, company or subdivision basis
Enter all subcontracts awarded under any prime or
subcontract with that agency for 6 month (if required) and
one year period
Not cumulative like the ISR
Not a sum of the company’s SF 294 reports
(because the SF 294 is from inception of contract and SF 295 is for a 6
month or one year reporting period)

SSR Reports
Always includes indirect costs
Do a separate SSR for every agency you one or more
subcontracting plans with (DoD is one agency except
construction: broken down by DOD component).
Except for commercial plan-holders: state percentage to each
agency on the same SSR report
You must certify that the CEO has approved the SSR
Required to retain a copy signed by the CEO on file

SDB Report
Separate report in eSRS
Due Annually for the period ending September 30
Subcontracts awarded to SDBs for the year, broken out by
NAICS code
due by Dec 31 st each year

SBA Contacts
Stephanie Lewis (North and East Texas – Fort Worth)
817-684-5303
Stephanie.lewis@sba.gov
Sophia Chou
817-684-5304
Shufang.chou@sba.gov
Other SBA representatives:
www.sba.gov/gc, Click on Contacts and Representatives