Subcontract Reporting Subcontracting Data Process Highlighted Issues Incorrectly Submitted Reports Status of DoD FY 2012 Reports Resources DoD
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2 Subcontract Reporting Subcontracting Data Process Highlighted Issues Incorrectly Submitted Reports Status of DoD FY 2012 Reports Resources DoD Regional Councils DoD Comprehensive Subcontract Plan 2
3 Contract requires Subcontracting Plan Contract coded as such in Federal Data Procurement System (FPDS) Subcontract Plan includes (among others) Reporting Requirement Flow-down requirement for Subcontract Plan to subcontractors 3
4 Prime contractors and subcontractors submit reports Government reviews prime contractor s reports Upper-tier contractor reviews its next lower-tier subcontractor s reports Subcontracting data is available for government s use 4
5 1. Multiple processes for collecting subcontracting data ISR in esrs SF 294 for contracts not entered in FPDS (FAR (Alternate III) Orders under BOAs or BPAs (G/H or A contracts) (Class Deviation - esrs, 2008-O0008, 12 Feb 09) 5
6 2. Different reporting requirements under different Subcontracting Plans ISR/SF 294 only required under Individual Subcontract Plan, not Commercial or DoD CSP SSR required under all 3 type plans 6
7 3. Contract must be coded correctly in FPDS in order to submit ISR in esrs Subcontract Plan must be coded Required Alert your Contracting Officer to make correction in FDPS 7
8 4. SSRs: (a) submitted under Individual Subcontract Plan encompasses all subcontracting performed in the US under DoD prime contracts and subcontracts, regardless of $ value 8
9 Sources of Subcontracting $ on SSR (reported under Individual Subcontract Plan) Contracts not Reported in FPDS When Prime Contractor Contracts under Global/Parent DUNS # When Subcontractor Contracts w/ Subcontract Plans Indirect subcontracts Contracts w/o Subcontract Plans Contracts - place of performance outside US, subcontracting performed in US
10 4. SSRs (cont.) (b) submitted under Commercial Subcontract Plan encompasses all subcontracting performed in the US for entire product line or service as negotiated in the subcontract plan and includes % of total subcontracting dollars attributable to each federal agency 10
11 4. SSRs (cont.) (c) submitted under DoD CSP encompasses all subcontracting under DoD prime contracts and subcontracts; may include subcontracting for departments/ agencies and DoD programs, as negotiated under the CSP 11
12 1. Contractors submitting multiple SSRs (same $) for DoD, under same DUNS #, same reporting period 2. Contractors submitting SSRs to organization(s) not authorized to acknowledge receipt or accept SSR(s) 12
13 Submit one SSR (Individual Plan, not construction/maintenance related) for DoD to the department or agency that administers the majority of your plans Most likely DCMA Must be department/agency directly under DoD Not DCMA-EAST, NAVAIR, DLA Energy, USACOE, AMC, NAVSUB, 13
14 Submit separate SSRs (Individual Plan, construction/maintenance related) to each department or agency that awarded such type contracts Must be department/agency directly under DoD Not DCMA-EAST, NAVAIR, DLA Energy, USACOE, AMC, NAVSUB, 14
15 3. Contractors submitting SSR under Commercial Subcontract Plan for construction/maintenance type work Commercial Subcontract Plan is for commercial products, manufacturing, or services; not for commercial construction or renovation of commercial spaces. 15
16 4. Subcontractors submitting SSR under Commercial Subcontract Plan To have a Commercial Subcontract Plan a contractor must have a government prime contract with a Commercial Plan. If a contractor does not have a prime contract, then he does not submit an SSR as a subcontractor. 16
17 5. Contractors submitting an SSR under Commercial Subcontract Plan showing percentages attributable to government agencies that are greater than 50% The total subcontract $ cover the entire production of products for the company, of which the government should be a small % of those $. 17
18 6. Contractors submitting SSR for the second reporting period with total $ less than the SSR submitted for the first reporting period. 7. Contractors submitting SSR/ISR with $0 in socioeconomic categories and no comment or explanation in the remarks section. 18
19 Status of DoD FY 2012 Reports Pending Review Accepted Rejected ISRs Prime , ISRs Sub 2,260 4, SSRs Individual SSRs Commercial 88 2, SSRs CSP
20 Guidance documents posted on OSBP website; choose esrs in drop-down menu under SB Specialists Tips for DoD Contractors Submitting Subcontracting Reports (Aug 2012) DoD Subcontracting Program: The Basics (Aug 2012) 20
21 DOD REGIONAL COUNCILS 21
22 DoD Regional Council Website to go live April 2013 Single point for members from to connect virtually Conduit for notifications/contacts to assist with implementing your small business programs 22
23 Develop standards across the councils Utilize the Regional Councils to support Mr. Kendall s Defense Acquisition Workforce Improvement Initiative (Sept 11, 2012) Utilize Councils to provide training Government Small Business Professionals Industry Small Business Professionals Resource Partners Small Business Professionals 23
24 2013 Training Plan: OSBP to assist all seven Regional Councils with training May 20-21: Annual training session for all members, all councils in conjunction with DoD Small Business Training Week (May 20-24, Dallas, TX) One training session for each Regional Council One virtual training session for each Regional Council 24
25 DOD COMPREHENSIVE SUBCONTRACTING PLAN (CSP) TEST PROGRAM 25
26 CSP Test Program authorized through Dec 31, 2014 Report to Congress the results of test (March 2013) Analyzing alternatives to consider as replacements to the CSP Developing transition plan Reviewing DoD s Subcontracting Program 26
27 27
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