8-sblos arthur mcdonald

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The University of Texas at Austin

Arthur A. McDonald

HUB/SADBO Coordinator-Director/Small Business Plan Administrator

Annette Smith

HUB/SADBO Staff Associate

John Trevino


Tiffany Dockery


Small Business Subcontracting Program


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Small Business Program

Subcontracting Plan Requirements

Subcontracting Plan Review

Evaluate Subcontracting in Source Selection

New Small Business Program Changes

Subcontracting Plan Implementation

Master Subcontracting Plans

Subcontracting Program


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Small Business Program

Policy:

To place a fair proportion of the

Universitys acquisitions, including contracts and

subcontracts, with small business, service-disabled

veteran-owned small business, veteran-owned small

business, HUBZone small business, small

disadvantaged business and women-owned

small business concerns.


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Policy:

It is further the policy of the University of Texas

at Austin that its prime contractors establish procedures to

ensure timely paymentof amounts due pursuant to termsof their subcontract with small business, service-disabled

veteran-owned small business, veteran-owned small

business, HUBZone Small business, small and

disadvantaged business and women-owned small businessconcerns.

FAR 19.702


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What is Small?

Type of Business

Construction

R&D-

R&D AircraftEducational

Engineering Services (Military)

Engineering Services (General)

Management ServicesComputer Programming

Computer Equipment

Not to Exceed

$ 17 Million Annually*

500 Employees

1500 Employees$ 5 Million Annually

$ 20 Million Annually

$ 2.5 Million Annually

$ 5 Million Annually$ 18 Million Annually

1000 Employees

* Annually - Average annual receipts over a three-year period


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Subcontract Coding and Size StandardsNorth American Industry Classification System (NAICS) replaces Standard

Industrial Classification (SIC) Codes effective 1 October 2000

Available at http://www.sba.gov/size/indextableofsize.html

Examples:

Industry SIC Code NAICS Size Standard

R&D 8731 541710 500 employees

Chemicals 2819 325188 1000 employees

Engineering 8711 541330 $ 4 Million Annually

Admin Services 8741 561110 $ 5 Million Annually
http://www.sba.gov/size/NAICShttp://www.sba.gov/size/indextableofsize.htmlhttp://www.sba.gov/size/NAICShttp://www.sba.gov/size/indextableofsize.htmlhttp://www.sba.gov/size/NAICS


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Subcontracting Program Implementation52.219-8 Utilization of Small Business Concerns

In all solicitations and contracts expected to exceed simplified acquisition

threshold except:

For personal services

Performed entirely outside the United States

52.219-9 Small Business Subcontracting Plan

When contracting by negotiation or sealed bid

Subcontracting possibilities exist

Cumulative value expected to exceed $ 500,000 ($ 1M construction) except:

From small business concerns HBCU/MI/TCUs for DOD contracts (DFARS 252.219-7003)

For personal services contract

Performance entirely outside the United States

52.219-10 Incentive Subcontracting Program


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Goals FY 02Small Business 23.0%

Veteran-Owned Small Business 3.0%

Service-Disabled VOSB 3.0%

HUBZone Small Business 2.5%

Small Disadvantaged Business 5.0%

Women-Owned Small Business 5.0%

Acceptance of an SDB goal of less than 5% requires approval two levels above PCO

(DFARS 219.705-2)


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Subcontracting Plan Requirements

1. Separate percentage goals for small business (SB). Veteran-

owned small business (VOSB), service-disabled veteran-owned

small business (SDVOSB), HUBZone small business, small

disadvantaged business (SDB) and women-owned smallbusiness (WOSB) concerns.

2. Statement of total dollars planned to be subcontracted for SB,

HUBZone, SDB, SDVOSB,VOSB and WOSB concerns.

3. Description of principal types of supplies and services to be

subcontracted and identification of types planned for

subcontracting to each small business entity.

4. Description of method used to develop goals.


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Subcontracting Plan Requirements(Continued)

5. Description of method(s) used to identify sources

Existing source lists

SBAs PRO-Net and SBAs

https://eweb1.sba.gov/hubzone/internet/web site National Minority Purchasing Vendor Information Service

Small Business Trade Association

6. Statement regarding inclusion of indirect costs in goals

7. Name of individual administering subcontracting program Employed by offeror

Description of duties

8. Description of efforts to ensure small business entities have the

opportunities to compete
https://eweb1.sba.gov/hubzone/internet/https://eweb1.sba.gov/hubzone/internet/https://eweb1.sba.gov/hubzone/internet/https://eweb1.sba.gov/hubzone/internet/


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Subcontracting Plan Requirements(Continued)

9. Assurances that clauses are included in subcontracts

52.219-8 Utilization of Small Business Concerns


10. Assurances that offeror will:

Cooperate in studies and surveys

Submit periodic reports:

SF 294 - Subcontracting Report of Individual ContractSF 295 - Summary Subcontract Report

Ensure subcontractors agree to submit SF 294 and SF 295

reports


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Subcontracting Plan Requirements(Continued)11. Recitation of types of records maintained:

Established source lists

Efforts to locate SB, SDVOSB, VOSB, HUBZone SB, SDB and

WOSB concerns

Organizations contacted to locate small business sources

Records on each subcontract solicitation/award of $100,000 or more:Were SB, SDVOSB, VOSB, HUBZone SB, SDB and WOSB concerns solicited?

If not, why not?

Reason not awarded to small business

Records of outreach efforts Records of internal guidance, encouragement to buyers, training and

monitoring program compliance

Records to support award data submitted to Government

Name, address and business size of each subcontractor

On contract-by-contract basis


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Subcontract Plan Review

Contracting Officer

1. Reviews, Obtains Advice and Recommendations from:

SADBO and ACO SBA Procurement Center Representative

2. Rejects, Negotiates, Accepts

Acceptability based on:

1. ALL Essential Elements Included2. Offerors Past Performance

3. Attainable Goals relative to:

Subcontracting opportunities

Pool of Eligible subcontractors available

Offerors actual subcontracting plan execution


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Subcontract Plan Review(Continued)

Acceptability based on:

Subcontracting Potential considering:

Make-or-buy policy

Nature of subcontracted products/services

Availability of SB, SDVOSB, VOSB, HUBZone SB, SDB

(HBCU/MI/TCUS) and WOSBs in area of work performanceOfferors relationship with its suppliers

Are separate goals included for each option period?

Are subcontracting goals realistic?

Are goals consistent with cost or pricing data?


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Evaluation of Subcontracting in Source Selection

SDB participation in unrestricted acquisitions expected to exceed $500,000( FAR 15.304 (c) (4) )

In acquisitions requiring FAR 219-9 Small Business Subcontracting Plan

For acquisitions other than those based on lowest price technically acceptable

process ( DFARS 215.304 (c) (i) )

Structure source selection criteria to allow for consideration of offers from SBs

Evaluation may be separate from Subcontracting Plan

Ensure SBs, HBCU/MI/TCUs and WOSBs are listed in subcontracting plan


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Evaluation of Subcontracting in Source Selection(Continued)

Evaluation of commitment to and extent of participation in performance of

contract by SBs and HBCU/MI/TCUs

Factors may include:Extent firms are specifically identified

Extent of actual commitment to use such firms

Extent of participation compared to value of acquisition

Complexity and variety of work firms are to perform

Realism of proposal

Prior performance regarding compliance with:

52.219-8 Utilization of Small Business Concerns



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Evaluation of Subcontracting in Source Selection(Continued)

Contract Administration

Substitution of Subcontractors:

SB, SDB, WOSB firms identified in plans

Contractor must notify ACO in writing of substitution

within reasonable period of awarding subcontract

Notice in contractor format


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New SB Program Change

SDB Participation Program

- Source Selection Evaluation of SDB participation

- Incentive Subcontracting Program for SDBs HUBZone Small Business Program

Service-Disabled Veteran-Owned Small Business Program


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SB Participation ProgramMechanisms to evaluate extent of participation of SDBs for

contracts in NAICS (formally SIC) major groups:

Source selection evaluation factor of sub-factor for SDB

participation in performance of contract

Evaluation factor considerations:

Extent SDBs are specifically identified in proposal Extent of commitment to use of SDBs

Complexity and variety of work SDBs will perform

Realism of proposal

Past performance of offerors complying with subcontracting plan goals

Extent of SDB participation compared to value of acquisition


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SB Participation Program(Continued)

Proposals must include SDB targets in dollars and percentage by

NAICS major groups of total contract value

Targets incorporated in resulting contract

SDBs listed in contract SDBs must be certified by SBA (http://pro-net.sba.gov)

Provisions and clauses:

- 52.219-24 Small Disadvantaged Business ParticipationProgram - Targets- 52.219-25 Small Disadvantaged Business Participation Program -

Disadvantaged Status Reporting

Report on SDB target achievement at contract completion- Contractor format

- Optional Form 312

- May be submitted with final SF 294, Subcontracting Report for Individual

Contracts
http://pro-net.sba.gov/http://pro-net.sba.gov/http://pro-net.sba.gov/http://pro-net.sba.gov/


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SB Participation Program(Continued)

Incentive Subcontracting with SDBs- Encourage increased subcontracting opportunities in NAICS

major groups

- Monetary incentives based on actual achievements compared totargets

- Separate from SDB subcontracting plan goals

- Clause

52.219-26 Small Disadvantaged Business Participation

Program - Incentive Subcontracting


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Historically Underutilized Business Zone Program

Purpose:To provide contracting assistance for qualified SBs located inhistorically underutilized business zones to increase employment

opportunities, investment and economic development

Applies to all federal agencies after 30 September 2000

Status as HUBZone Small Business:- Determined by SBA

- Must be listed on SBAs website:

http://www.sba.gov/hubzone
http://www.sba.gov/hubzonehttp://www.sba.gov/hubzone


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Veteran-Owned Small Business

Purpose:Provide new assistance programs for veterans and service-disabled veterans who own and operate businesses

Establishes:Service-Disabled Veteran-Owned Small Business primecontract goal and Veteran-Owned Small Business subcontracting goal

Effective: 11 October 2000

Statute:Veterans Entrepreneurship and Small Business Development Act of1999 (P.L. 106-50)


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Subcontracting Plan Implementation

Contractor performs following functions:

Assist SBs, SDVOSBs, VOSBs, HUBZone SBs, SDBs and WOSBsconcerns to facilitate participation

Provide adequate and timely consideration of small business entities

capabilities

Counsel and discuss subcontracting opportunities with small business

representatives

Provide notice to subcontractors concerning penalties and remedies

misrepresentation of status

S i


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52.219-10 Incentive Subcontracting Program

Monetary incentive to increase subcontracting opportunities forSB, HUBZone SB and WOSB concerns

Prime receives percentage of excess at contract completion

PCO determines amount to be paid based on contractors efforts:

- Unique outreach programs

- Technical assistance to SB entities

Determinations NOT subject to dispute clause

If CPFF contract, sum of fixed fee and incentive fee earned cannot exceed fee

limitations (FAR 15.404-4)

S b i P


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Subcontracting Plan ReportingSF 294 - Subcontractor Report for Individual Contracts

Required under Small Business Act of 1958

- Semi-annually

- For each contract over $500,000 with subcontracting plan

Submitted to the Contracting Officer awarding the contract (Block 8)

Copy to cognizant contract administration office (Block 6 )

SF 295 - Summary Subcontract Report

Required under Small Business Act of 1958- Contractor has one or more contracts with subcontracting plan(s)

- Semi-annual for DOD - Annually for Civilian Agencies

- Commercial products plan - Annually

- Reports submitted to individual agencies

Report all subcontracts awarded

S b i P


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Subcontracting Plan ReportingDistribution

DOD

Send to cognizant contract administration office

NASA

Office of Procurement (HS), Washington, DC 20546

Other Federal Departments or Civilian Agencies:

Office of Small and Disadvantaged Business Utilization oras instructed by the Department or Agency

S b i P


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Master Subcontracting Plans

University-wide basis

Contains all elements of plan exceptgoals

Approved by ACO

Valid for three years

Develop goals for individual contracts

8-sblos arthur mcdonald

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