Industry Meeting Schedule 23V & Schedule 751 October 18, 2018

1. Industry Meeting Schedule 23V & Schedule 751 October 18, 2018

2. Agenda • Subcontracting Plans • General • What we look for • Electronic Subcontracting Reporting System • When to submit reports • What to submit • Resources • Questions and Answers

3. Subcontracting Plans – General • Required by FAR 19.7 – The Small Business Subcontracting Program • Estimated contract value exceeds $700,000, inclusive of all options, whether exercised or not • “Other than small business” • Any contractor or subcontractor failing to comply in good faith with the requirements of the subcontracting plan is in material breach of its contract. • Failure to make a good faith effort can result in the imposition of liquidated damages.

4. Subcontracting Plans – General • FAR 52.219-9 lists the subcontracting plan requirements: • Percentage goals for using SB, VOSB, SDVOSB, HUBZone SB, SDB, WOSB • Total dollars and description of what will be subcontracted • Method used to develop subcontracting goals • Method used to identify potential sources • Reports • Responsibilities of Plan Administrator • Assurances

5. Terms and Conditions • FAR 52.219-8, Utilization of Small Business Concerns • FAR 52.219-9, Small Business Subcontracting Plan • FAR 2.219-16, Liquidated Damages

6. Subcontracting Plans – General • Two types of subcontracting plans • Commercial - means a subcontracting plan (including goals) that covers the offeror’s fiscal year and that applies to the entire production of commercial items sold by either the entire company or a portion thereof ( e.g., division, plant, or product line). • Individual - means a subcontracting plan that covers the entire contract period (including option periods), applies to a specific contract, and has goals that are based on the offeror's planned subcontracting in support of the specific contract. • GSA’s Model Subcontracting Plan

7. Subcontracting Plans – What we look for • Realistic Goals, yet a “stretch” • Compared to current plan and reported achievements • Proper credit to all socio-economic categories • Sound plan for finding small businesses • Points of Contact and Signatures • All plans are reviewed by the CO, GSA Office of Small Business Utilization and the Small Business Administration

8. Credit to all socio-economic categories-Example • $100,000 subcontract to a WOSB who is also a SDVOSB would be credited in both plan and reports: • -$100,000 to WOSB • -$100,000 to SDVOSB • -$100,000 to VOSB since SDVOSB is also a VOSB • -$100,000 to SB since WOSB/SDVOSB is also a SB

9. Electronic Subcontracting Reporting System (eSRS) • Vendors are required by FAR 52.219-9 to • Submit periodic reports so that the Government can determine the extent of compliance by the offeror with the subcontracting plan • Submit the Individual Subcontract Report (ISR), and the Summary Subcontract Report (SSR) using the Electronic Subcontracting Reporting System (eSRS) (http://www.esrs.gov), following the instructions in the eSRS.

10. Electronic Subcontracting Reporting System (eSRS)

11. Reporting Dates to Remember- Individual Plans • 1. Individual Subcontracting Reports (ISRs): • For period ending March 31, NLT April 30 • For period ending September 30, NLT October 30 • Final ISR- within 30 days of contract completion • 2. Summary Subcontracting Report (SSR), “summarizes” subcontracting under all GSA contracts- NLT October 30 • Note: Revised reports must be submitted within 30 days of CO rejection.

12. Reporting Dates to Remember- Commercial Plans • One report only, SSR due NLT October 30 • “summarizes” all corporate subcontracted $$$ • Avoid mistakes in commercial plan reporting by using the “Quick Reference Guides” on eSRS home: • -Report all corporate subcontracted dollars • -Properly allocate small % to federal agencies • -List all DUNS numbers covered by the plan • -Explain shortfalls

13. Electronic Subcontracting Reporting System (eSRS) • Best Practices when submitting a report in eSRS • File the reports timely and accurately • For individual plans, file reports even when there has been no subcontracting during the period • Choose “Federal Acquisition Service” instead of General Services Administration • Do not leave blank fields – even if you did not subcontract to a certain group listed do not leave it blank – enter 0 in these cases. • For commercial plans, include ALL subcontracted dollars (federal and non-federal) and allocate the federal dollars as instructed

14. eSRS Best Practices (continued) • Justify in the remarks area for all instances where a 0 is entered or when the goal on your subcontracting plan was not met. • Indicate corrective action to be taken to increase subcontracting in those areas. Tell the story! • Avoid repeated use of same reasons year after year. • Make sure the Agency CO that approved the commercial subcontracting plan is the one identified to approve the eSRS report. • Ensure email addresses of all the CS/COs for contracts that require a subcontracting plan are listed.

15. Where to find small businesses? • SBA Dynamic Small Business Search • Local chambers of commerce • State, county and local government minority offices • Procurement Technical Assistance Centers: http://www.aptac-us.org/ • SBA Commercial Marketing Representative (CMR): • https://www.sba.gov/contracting/resources-small-businesses/cmr-directory

16. Resources to Understand Subcontracting • T&Cs of the contract, especially FAR 52.219-9 • GSA Model Subcontracting Plan • FAR subpart 19.7 and GSAM 519.7 • Local SBA CMR • Guides on eSRS home page

17. Questions and Answers

18. Contact information • Deborah Eble • GSA Subcontracting Program Manager • 215-446-5823 or deborah.eble@gsa.gov