VAs Thriving Through Partnership Industry Conference

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Small Businessthe Engine that drives Americas
economy

• VAs Thriving Through Partnership Industry
  Conference
• October 3-4, 2005
• Subcontracting Plans and You

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Small Business Goals and How They Are Set

• Statutory
• SBA/VA-Negotiated
• Secretarys Goals

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Small BusinessThe Statutory Goals

• Small Business Concerns (23)
• Small Disadvantaged (5)
• Women-Owned (5)
• HUBZone (3)
• Service-Disabled Veteran-Owned (3)

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Small Businessthe Secretarys Goals
(FY 04)

• Small Business Concerns (35)
• Small Disadvantaged (5)
• Section 8(a) SDB (5)
• Women-Owned (6)
• HUBZone (3)
• Service-Disabled Veteran-Owned (3)
• Veteran-Owned (7)

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SUBCONTRACTING PROGRAM
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Statutory Requirements

• FAR 19.702
• Required when the contract award or mod will
  exceed 500 K (1M for construction) AND awardee
  is a large business.

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What Goes In A Subcontracting Plan?

• FAR 19.704
• 11 Required Elements

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Required Elements

• (1) SEPARATE Percentage goals for small
  business, HUBZone small business, small
  disadvantaged business, women-owned small
  business, veteran-owned and service-disabled
  veteran owned business
• (2) Total dollars to be subcontracted and a
  statement of the total dollars to be
  subcontracted to the small business types listed
  in (1).
• (3) Description of the principal types of
  supplies and services to be subcontracted and an
  identification of those planned for
  subcontracting to the identified small business
  types.

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Required Elements

• (4) A description of the method used to develop
  the subcontracting goals.
• (5) A description of the method used to identify
  potential sources for solicitation purposes
• 6) A statement as to whether or not offeror has
  included indirect costs in establishing
  subcontracting goals, and a description of the
  method used to determine the proportionate share
  of indirect costs to be incurred with small
  businesses.
• (7) The name of the CONTRACTORs employee who
  will administer the offerors subcontracting
  program, AND, a description of that individuals
  duties.

10
Required Elements

• (8) A description of the efforts the offeror
  will make to ensure that small businesses of all
  types have an equitable opportunity to compete
  for subcontracts.
• (9) Assurances that the offeror will include the
  clause at 52.219-8 (flow-down clause) in all
  subcontracts that offer further subcontracting
  opportunities and that the offeror will require
  all LARGE subcontractors who receive subcontracts
  over 500K (1M for construction) to adopt a plan
  IAW 52.219-9.

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Required Elements

• (10) Assurances that the offeror will--
• Cooperate in any studies or surveys
• Submit periodic reports so Government can
  determine extent of compliance with the plan
• Submit Standard Form 295 and 294, as appropriate,
  IAW form instructions
• (11) A description of the types of records
  maintained concerning procedures adopted to
  comply with the requirements and goals in the
  plan, including source lists, and a description
  of the offerors efforts to locate and award
  subcontracts to all types of small business
  concerns.

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FAR 15.304  Evaluation factors and significant
subfactors

• Section (C ) (3)(iii) For solicitations involving
  bundling that offer a significant opportunity for
  subcontracting, the contracting officer must
  include a factor to evaluate past performance
  indicating the extent to which the offeror
  attained applicable goals for small business
  participation under contracts that required
  subcontracting plans (15 U.S.C. 637(d)(4)(G)(ii)).
  

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FAR 15.304  Evaluation factors and significant
subfactors

• ( C)(5) For solicitations involving bundling that
  offer a significant opportunity for
  subcontracting, the contracting officer must
  include proposed small business subcontracting
  participation in the subcontracting plan as an
  evaluation factor (15 U.S.C. 637(d)(4)(G)(i)).

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FAR 15.305 Proposal Evaluation

• (a)(5) Small business subcontracting evaluation.
  Solicitations must be structured to give offers
  from small business concerns the highest rating
  for the evaluation factors in 15.304(c)(3)(iii)
  and (c)(5).

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Reporting Requirements

• Standard Form 294
• Standard Form 295

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Standard Form 294

• Subcontracting Report for Individual Contracts
• Not for Commercial Plans
• Not required from small businesses
• Submitted semi-annually 30 days after close of
  each reporting period
• Reporting periods end March 31st and Sep 30th

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Standard Form 295

• Summary Subcontract Report
• Used for commercial and individual plans
• due on October 30th each year for the previous
  fiscal year ended Sep 30
• Separate report is required for EACH Federal
  Government agency, covering only that agencys
  contracts