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  1. Hey everyone! Quick question: I am trying to figure out how the logistics of subcontractor oversight in terms of lower-tier subcontracting plans work in practice. Say my company (recently a large) is working on a bid with several subs, one of which is an OTSB with a subcontract over $650k triggering 52.219-9. Our typical subcontract template has a provision that explicitly says you can't subcontract without express consent from us...I will assume this will need to go and be replaced with some type of contract provision regarding the subcontract plan requirement (anyone got any sample language?). A few pointed questions at this point: 1. If this subcontractor says they don't want to subcontract the work out any further, and says "there are no further subcontracting opportunities" ....how should we go about getting that determination? Is that one level above the prime at the CO level? Can we make that call? How should we document? 2. Even if there are opportunities, the slice of pie has gotten much smaller and they will likely not be looking to add multiple subs onto their agreement, so I figure they will be hitting a lot of 0% in their goal categories....if we set the goals at a standard-type level (3% WOSB, 2% HUB, etc.) knowing they won't be getting near these....is this a bad look for us/them? How should we handle this situation? Thanks so much guys....we are just new to the area and want to have our ducks in a row before this stuff actually comes to fruition. Thanks so much for your anticipated assistance.
  2. This is great! I think we are on the right track then. Thanks everyone! here_2_help...just for clarification, When you state: "Generally, the Agency to which you submit proposals will have clear guidance that tells bidders what its commitments are, which are also its expectations. If you want a favorable reception, you should plan to support the Agency's overall commitments" (emphasis added)...are those commitments in terms of a percentage of subcontracting dollars, or in total amount of money given to smalls? At this point, at least in the current bid, we should reach any overall smalls percentage they throw at us...but I just want to ensure we don't need to be going out and looking to subcontract more work because we potentially haven't planned to sub enough of the work out in general.
  3. Thank you here_2_help! That is very helpful...a lot of our uncertainty stems from us simply not knowing how this process works and what to expect. At this point, we are currently lining up a bid with approximately 4 subcontractors working with us...all of them are small. One is HUBZone and a couple are WOSB. We do not have any that are veteran or service disabled owned.....I can't tell you exactly how big of slices these subs will be getting of the whole pie, but they are likely to be the only subs we work with. What are your thoughts on our situation? Should we be reaching out for some VOSBs, etc.? I think we are all on edge and not sure how we are doing, and unfortunately there isn't a CMR in our region to really get in contact with to ask questions. Any suggestions for me? Thanks again for your help; I really do enjoy these forums they are a huge help for people new to the arena.
  4. Hey everyone! Background: I'm fairly new to the contracting world and working in a recently-large prime contractor in the healthcare sector. I've been helping prepare ourselves for our first bid season as a Large contractor and now under the pressure of compliance with FAR 52,219-8 & -9, etc. For a while I was under the impression that our small business subcontracting goals were to subcontract out roughly 30% of the total contract dollars to smalls...I am recently been corrected (and now it I see my mistake everywhere) that we are only under an obligation that 30% of our dollars subcontracted must go to smalls. First off, my new understanding is correct, right? Goals are in terms of total subcontracting dollars? (Ie. $1,000,000 contract, $100,000 subcontracted, $30,000 to smalls). Second, do any of you have any general practice tips as far as what percentages of TOTAL dollars should be subcontracted? I know that is extremely tough to even ballpark given the various subject matter and scope of Prime contracts...but wasn't sure if there was sort of a "floor" that you want to avoid, for example, subbing less than 10% of your total dollars out if you want to keep the SBA away. Thanks for your time! Like I said, I'm new to this whole thing (as is my company) so any help is appreciated. nebraska
  5. We are dealing with ABC...they are the authorized dealer of FP's products. Just trying to figure out if there is any way we can claim the money spent as to a small because ABC (the dealer) is small.....although it is a FP product, and using an FP agreement.
  6. For purposes of small business goals under a subcontracting plan, my question relates to small vendors who are authorized retailers for larger businesses. We are relatively new to the "large prime" game and are still awaiting our first win as a big (cross our fingers it is soon)...we plan on allocating indirect costs and are attempting to get those numbers and vendor size classifications settled here early. My question: We have come across an office supply/equipment store, a local small here in town (for our purposes, I will refer to it as ABC Equipment). ABC Equipment is an authorized retailer for FP mailing solutions, a large. We go to rent a postage meter from ABC and the agreement comes back with the FP letter head and template. Can we consider this transaction as business with a small? Is it who we buy from or who we contract with? At first blush and without any support, I feel as though this transaction would further the government's end of promoting small businesses by growing ABC Equipment....but hopefully you can see the dilemma. Anyone have any guidance? As always, I humbly thank you for your help and patience! Nebraska.
  7. Very broad question here guys: How do you go about defining Personally Identifiable Information (PII)? We have a new systems security guy who is very stringent in his definition; even going so far as to flag an email where an internal employee sent our outside customer a list of 10 names (with emails and phone numbers for each)....those 10 names were employee and/or outside individuals who were willing to serve on a committee (no information came from a system of records). I was acting under the assumption that the Privacy Act governed PII in terms of working with federal contracts but the new guy is talking a lot about "ISP Standards" and other CMS guidance. How do you guys handle PII? Any resources you could point me to to help us set some standards and limits on the PII definition? Thanks for the help!
  8. We will not be subject to a commercial plan of any sort...the SBLO Handbook is the Small Business Liaison Officer Handbook and has been a very useful tool in learning this entire realm. In the manual, the section speaking to Master plans is listed immediately following the Commercial Plan section, and hence the comparative language: "As in the case of a Commercial Products Plan, a Master Plan..." I believe we have the Master Plan well drafted, it was more of a logistical issue on how and when to submit which I think I have nailed down now. Thank you though. Found at: http://www.sba.gov/sites/default/files/Small_Business_Liaison_Officer_(SBLO)_Handbook_6_2010.pdf
  9. I think I may have jumped the gun and I simply didn't take advantage of the resources I had prior to posting. I just found this language in the SBLO Handbook (2010): "As in the case of a Commercial Products Plan, a Master Plan must be approved by the first Federal agency awarding the company a contract requiring a subcontracting plan during the fiscal year. A Master Plan is effective for three years; however, when incorporated into an individual plan, a master plan applies to that contract throughout the life of the contract" (Emphasis added). I guess we are just waiting until that first contract comes along. Sorry for the inconvenience, but I really do appreciate you taking a look ji20874. Thanks for your patience.
  10. I have...but maybe I am misunderstanding it. The relevant part is at 19.704( b ): "Contractors may establish, on a plant or division-wide basis, a master plan (see 19.701) that contains all the elements required by the clause at 52.219-9, Small Business Subcontracting Plan, except goals. Master plans shall be effective for a 3-year period after approval by the contracting officer; however, it is incumbent upon contractors to maintain and update master plans. Changes required to update master plans are not effective until approved by the contracting officer. A master plan, when incorporated in an individual plan, shall apply to that contract throughout the life of the contract" (Emphasis added). Have I misinterpreted the use of the Master Plan? Or must we wait until our first contract requiring a plan comes along? I really do not think I am comprehending this area as it's all brand new to me, so I apologize if I come off as incredibly ignorant and/or misguided.
  11. Hey guys: My company has prepared a Master Subcontracting Plan (our first), but we want to get it approved before any contracts require a plan so that we can focus strictly on the goal aspect at that time rather than the entire plan (sort of the point of the Master as far as I can tell). Anyone have any idea who or where we are to send this to for approval? If on a specific contract I would assume we would work toward approval with the CO, but being a blanket Master plan, I do not really know if this should be going to the SBA, or to CMS (our main customer), or someplace else. Any contact information would be helpful. I was under the impression we could get a Master Plan approved for 3 years rather than doing individual plans on each contract.....and once again, my local PCR was not very helpful and I am not sure who represents us here in Nebraska as a CMR, so I have attempted to reach out to the SBA itself. Thanks again for taking the time to assist!
  12. In terms of a Sole Proprietorship being somehow fundamentally different than an individual, the IRS has stated that an EIN is not necessary for a sole proprietorship. An SP can exist without an EIN. My thoughts are that by the very definition of an SP, an individual need not take any steps to create this type of business (unless some states out there require some type of name or business registration I am unaware of. Source: http://www.irs.gov/Help-&-Resources/Tools-&-FAQs/FAQs-for-Individuals/Frequently-Asked-Tax-Questions-&-Answers/Small-Business,-Self-Employed,-Other-Business/Form-SS-4-&-Employer-Identification-Number-(EIN)/Form-SS-4-&-Employer-Identification-Number-(EIN)-1
  13. I really apologize for losing track of this thread guys...I truly appreciate your help and opinions on this matter. When I emailed my local SBA PCR I told him we had several independent contractors already in place (assuming they are properly classified...we have had some issues with classifications before, but that is not at issue here), and asked if my assumption that they could be counted in our goals was correct based on the definition of "business concerns" at 13 CFR 121.105. His response is below; and yes, he is always this short-winded: "Actually, the answer is “no”. There is a difference between an independent contractor and small business. The small business would need to be registered as an “S” corporation or something. But they would need to figure that out. It is more than a SAM registration. Thanks."
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