DoD Office of Small Business Programs Managing Your Subcontracting Program _________________________ Janice Buffler Associate Director, Subcontracting.

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Presentation transcript:

DoD Office of Small Business Programs Managing Your Subcontracting Program _________________________ Janice Buffler Associate Director, Subcontracting Policy and DoD Regional Councils

Agenda Introduction Subcontract Plans Subcontract Reports Resources Fact Sheets / Checklists for Subcontract Reports

Janice Buffler Associate Director DoD Office of Small Business Programs Subcontracting Policy 571-372-6333 Janice.l.buffler.civ@mail.mil

Subcontracting Plans -- Types Individual Subcontract Plan Commercial Subcontract Plan DoD Comprehensive Subcontract Plan Master Subcontract Plan

Subcontracting Plans – When? Contracts > $700K ($1.5M construction) AND subcontract opportunities exist Modifications > $700K ($1.5M construction) with new work AND subcontract opportunities exist Multi-year contracts / contracts with options Cumulative value of base contract & all options SEPARATE goals for base & each option

Subcontracting Plans – Whom? ALL other than small business: Large business State & local government Non-profit organizations, Including: UNICOR & Ability One In most cases Public utilities Educational Institutions Foreign-owned firms Gov’t entities (Labs)*

Sub Plans – When Not Required? From small businesses For personal services contracts For contracts / modifications performed entirely outside US & outlying areas For modifications to contracts within general scope of the contract that did not contain FAR 52.219-8 (or equivalent prior clauses, e.g., contracts awarded before enactment of PL 95-507) If no subcontract opportunities (approval at one level above CO is required)

Subcontract Plan – Elements Goals (% and $ based on total planned subcontracting overall & by category) Description of principle types of supplies & services to be subcontracted Description of method used to develop subcontract goals Description of method used to identify potential SB sources Indirect Costs (included/not included) & methodology used to determine proportionate share of indirect costs for each category

Subcontract Plan -- Elements Name of individual administering subcontracting program & description of duties Description of efforts to ensure SB has an equitable opportunity Assurances: Cooperate in studies / surveys Submit reports, as required Submit ISR (or SF 294) / SSR as required

Subcontract Plan Elements Record-keeping: description / procedures / process “Flow down” clauses & requirements for subcontract plans and related reports 52.219-8 (Utilization of SB Concerns) 52.219-9 (Subcontracting Plan)

Socioeconomic Categories Small Business (self-certify)* WOSB (self-certify) HUBZone (SBA-certified) VOSB (self-certify) SD-VOSB (self certify) SDB (self-certify)*

Subcontract Reports Individual Subcontract Plan ISR (semiannual) SSR (annual) Commercial Subcontract Plan DoD Comprehensive Subcontract Plan SSR (semiannual) Special reporting

Who Reviews Reports? ISR (Prime): Awarding Contracting Official ISR (Sub): Contractor awarding subcontract SSR submitted under Individual: SSR Review Team (OSBP/DCMA/DPAP) SSR submitted under Commercial Subcontract Plan: Contracting Official who approved Plan SSR submitted under DoD Comprehensive Subcontract Plan: DCMA CSP Team

ISRs Submit SF 294 in lieu of ISR FAR 52.219-9, Alternate III (July 2010) For contracts not entered in FPDS Class Deviation 2008-O0008-eSRS (Feb 2009) For orders under Basic Ordering Agreements or Blanket Purchase Agreements Contract must be coded correctly in FPDS in order for a contractor to submit ISR in eSRS

SSRs Class Deviation 2013-O0014 FAR 52.219-9(l)(2)(i)(C) and (D), SSRs submitted under an Individual Subcontract Plan Reduces the frequency of submission of the SSR submitted under an Individual Subcontracting Plan from biannual to annual Eliminates the requirement for multiple SSRs submitted under an Individual Subcontracting Plan for construction and related maintenance and repair contracts, so that only one, consolidated report encompassing all contracts is necessary

SSRs Class Deviation 2013-O0014 DFARS 252.219-7003 (a) and (h)(1)(ii), SSRs submitted under Individual Subcontract Plan Changes the definition for SSR Coordinator from department/agency to DoD Changes the entity to which the contractor submits the SSR in the Electronic Subcontracting Reporting System (eSRS) for an individual subcontract plan from the DoD department or agency (component) to DoD (9700)

Subcontract Reporting Update Class Deviation 2013-O0014 DFARS 252.219-7003 (h)(2) Removes the requirement for the “Year-End Supplementary Report for Small Disadvantaged Business” and the report for “Small Disadvantaged Participation” as these reports are no longer needed since 10 U.S.C. 2323 has expired

Resources http://www.acq.osd.mil/osbp/ Fact Sheets and Checklists: “The Individual Subcontracting Report (ISR): Required by Individual Subcontract Plan (June 2016)” “The Summary Subcontracting Report (SSR): Required by Commercial Subcontract Plan (June 2016)” “The Summary Subcontracting Report (SSR): Required by Individual Subcontract Plan (June 2016)” “DoD Subcontracting Program: The Basics (June 2016)” Fact Sheet “Tips for Contractors Submitting Subcontracting Reports (2015)”