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SBLO DUTIES. Inform and assist Buyers in locating and using appropriate Small Business concerns as sources of supply. Respond to inquiries from potential suppliers and ensure they are brought together with Buyers and other appropriate personnel who may be able to use their products and/or services.
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1. 2007 North Carolina PTAC Supplier Diversity Workshop Rhys Sueur
Senior Manager
Procurement Systems and Compliance
General Dynamics Armament and Technical Products
2. SBLO DUTIES Inform and assist Buyers in locating and using appropriate Small Business concerns as sources of supply.
Respond to inquiries from potential suppliers and ensure they are brought together with Buyers and other appropriate personnel who may be able to use their products and/or services.
Review subcontracts potential for Small Business participation.
Advocate for Small Business content in all "make-or-buy" decisions
3. SBLO DUTIES (cont) Participate in establishment of relevant subcontract goals and monitor performance.
Collect data and report on achievements as required.
Attend trade fairs and seminars for the advancement of Small Business concerns .
Assist in development of programs to expand contacts.
4. US Government Regulations and Policies
5. GOVERNMENT SMALL BUSINESS POLICY It is the policy of the United States that small business concerns, veteran-owned small business concerns, service-disabled veteran-owned small business concerns, HUBZone small business concerns, small disadvantaged business concerns, and women-owned small business concerns shall have the maximum practicable opportunity to participate in performing contracts let by any Federal agency, including contracts and subcontracts for subsystems, assemblies, components, and related services for major systems. It is further the policy of the United States that its prime contractors establish procedures to ensure the timely payment of amounts due pursuant to the terms of their subcontracts with small business concerns, veteran-owned small business concerns, service-disabled veteran-owned small business concerns, HUBZone small business concerns, small disadvantaged business concerns, and women-owned small business concerns.
6. FAR AND DFARS 52.219-8 – Utilization of Small Business Concerns
US Government policy and the requirement for prime contractors to follow it
52.219-9 – Small Business Subcontracting Plan
Requirement and content of plans
SF 294 and SF 295 submittal
Record keeping requirements concerning Small Business activities
7. FAR AND DFARS (cont) 52.219-16 – Liquidated Damages- Subcontracting Plans
Failure to make a good faith effort to attain the goals in the subcontracting plan
An amount equal to the actual dollar amount by which the contractor failed to achieve each subcontract goal
252.219-7003 – Small, Small Disadvantaged and Woman-Owned Small Business Subcontracting Plan (DoD Contracts)
Supplements FAR 52.219-9
8. GOALS BY PUBLIC LAW Small Business 23%
SDB 5%
Woman Owned 5%
HUBZone 3%
SDV 3%
Vet BE
HBCU BE
9. CERTIFICATION PROCESS HubZone – SBA
SDB – SBA
Small Business – Self
Woman Owned – Self
Veteran – Self
Service Disabled Vet - Self
10. Subcontracting Plans and Small Business Reporting
11. TYPES OF SUBCONTRACTING PLANS Commercial Plans – All the elements including goals have been negotiated for the Contractor’s fiscal year based on their estimate of commercial sales (294s not required).
Comprehensive Plans – DOD test program. All the elements including goals are negotiated on a company wide basis for all defense contracts (294s not required).
12. TYPES OF SUBCONTRACTING PLANS (cont) Master Plans – All the elements in the Subcontracting Plan have been negotiated except for the goals (294s required).
Individual Plans – All the elements including goals are negotiated for each required contract (294s required).
13. INDIVIDUAL SMALL BUSINESS SUBCONTRACTING PLANS Required for all contracts and subcontracts over $550,000 at any tier
Based on domestic subcontracting effort
Exceptions for small businesses, commercial products, personal service contracts, and contracts performed outside the United States with no subcontracts to US sources.
An SF 294 must be submitted for each individual plan in April and October
14. CONTENT OF PLAN Solicitation or Contract Number
Name of PCO/ Command/ Fax number
Percentage Goals and Subcontract $
Small Business
HUBZone Small Business
Small Disadvantaged Business
Women-Owned Small Business
Veteran- Owned Small Business
Service-Disabled Veteran-Owned Small Business
Historically Black Colleges or Universities or Minority Institutions
15. CONTENT OF PLAN (cont) If public law goals are not proposed in the plan, an explanation is required to include
Why the goals were not met or why the procurement did not lend itself to SB/ SDB
What efforts were utilized to attempt to meet the goals
Why these efforts were not successful
Future plans to include more small businesses in subcontracting opportunities
16. CONTENT OF PLAN (cont) Planned Supplies and Services
List all commodities planned to be subcontracted to Small Businesses and their corresponding dollar amounts
List the dollar amounts and commodities by the individual small business categories in the plan
Methods used to develop subcontracting goals
Method used to identify potential sources
Treatment of Indirect Costs
Name of plan administrator
17. CONTENT OF PLAN (cont) How Small Business Concerns have equitable opportunity to compete for subcontracts
Flowdown of FAR clauses
Cooperate in Studies
Submit SF 294 and SF 295 reports
Description of record keeping
Source lists
Subcontract solicitation and award for orders over $100K
Outreach efforts
18. SF 294 Required to be submitted to the cognizant DCMA and the customer by April 30th and October 31st
Type of Report – Regular, Final, Revised
Current Goal in $ and % are the goals in the accepted Small Business Subcontracting Plan
Actual Cumulative $ and % are the totals of all the domestic subcontracts in the performance of the contract
Final reports must include an explanation of why goals not achieved and Optional Form 312 on breakdown of SDB participation
19. SF 295 Required to be submitted to the cognizant DCMA by April 30th and October 31st
Company Information including Duns Number
Cumulative Fiscal Year Subcontract Awards
Name of SBLO
Signed by senior person in the company
20. DCMA Oversight
21. BARBARA LITTLE’S DCMA REVIEW POINTS Discuss current FY performance
Provide a comprehensive briefing on your 2006 forecast from bottom up
Strategic Sourcing Team that assists in forecasting
Goals for the current FY
Goals for the last three years
3 year performance against goals
22. BARBARA LITTLE’S DCMA REVIEW POINTS (cont) Effectiveness of outreach program. New small businesses that have been added as the result of outreach in the last two years
Sole source procurements that are Government/ contractor directed
Ensure the Small Businesses are able to compete in high-tech procurements
Small Business can find out what your company plans to procure
23. BARBARA LITTLE’S DCMA REVIEW POINTS (cont) Successes in redirecting business from Large to Small Businesses
Access to subcontract spend data in detail
Type of procurement system
Analysis of the subcontracting spend
24. SMALL BUSINESS REVIEW Normally annually
Conducted by the DCMA office where you send your SF 294s and 295s
DCMA Form 640
Company statistics on amount of DOD contracts
294 analysis
295 analysis
Company Small Business policies and procedures
Outreach efforts
25. SMALL BUSINESS REVIEW (cont) DCMA Form 640 (cont)
Subcontracting Plans
Compliance with FAR clauses
Company Small Business Policy Statement
SBLO appointment letter
Management involvement with Small Business Program
Small Business supplier lists
26. SMALL BUSINESS REVIEW (cont) Outstanding – exceeded at least one goal and met all others on all final SF 294s for the review period
Highly Successful – met all goals on all final SF 294s for the review period
Acceptable – demonstrated good faith effort to meet all goals and all reporting is complete and accurate
Marginal – deficient in meeting key subcontracting plan elements, reporting is not correct or accurate, failed to comply with corrective action plan.
Corrective plan required and ACO must be notified
27. SMALL BUSINESS REVIEW Unsatisfactory – non compliant with the public laws, FAR regulations, and reporting requirements. Management does not show interest in attaining an acceptable level.
Corrective plan required and ACO must be notified
28. Best Practices
29. DCMA BEST PRACTICES OF PRIME CONTRACTORS Establish team or working group to assign advocates that act as extension of Supplier Diversity program office
Utilization of Manufacturing Engineer to visit SDBs that had contacted SBLO regarding business opportunities
Publication of supplier diversity news
Appointment of business advocate for each diversity group
SBLOs formed a committee to better prepare subcontractors to do business with their companies
30. DCMA BEST PRACTICES OF PRIME CONTRACTORS (cont) Inclusion of small, disadvantaged and women-owned businesses in every procurement
Identification of where expenditures occurred so everyone, not only the buyer, knew to be on the lookout for small business sources in those areas
Approval to award to SDBs that were not the low bidder
Formation of re-sourcing team to establish policy and procedures to resource material from one supplier to another
Technology utilization
31. OTHER SUGGESTIONS Diary of all inquiries that come to SBLO
Retained records of all Small Business Subcontracting Plans
Spreadsheet
Email template to respond to suppliers on how to do business with GD
Supplier review boards
Commodity specific
Review and qualify suppliers
Identify diverse suppliers
32. OTHER SUGGESTIONS (cont) Internal website for buyers
Central repository of potential suppliers
Frequently asked questions
Points of contact
All internal employees have access
External website for suppliers
Government contract provisions
Terms and Conditions
Quality Codes
IUID Marking Instructions
33. HANDOUTS The Business Class Representation Form – sent to Suppliers for size certification and includes the FAR sites and definitions
Size Status Matrix – used to document solicitation and award to Small Business concerns
How to do Business with General Dynamics Armament and Technical Products – given to Small Business suppliers to help them through the process