I am under the impression that most Dept. of Defense RFPs include a requirement for a Small Business Subcontracting Plan (SBSP) from Large Businesses (LBs) when the FAR 19.7 criteria are triggered. In addition, most also require a Small Business Participation Plan (SBPP) from both Large and Small Business Offerors which is different from the SBSP. From what I have seen, the SBPP usually requires the Offeror to calculate the percentage of participation on total contract value (sometimes the offeror's price and sometimes the contract's ceiling value), while the SBSP usually requires the SB percentage of participation to be calculated using the value of the "total subcontracted dollars." (I say "usually" because of the Court of Federal Claims decision in FIrstLine Transportation Security, Inc, v. US, No. 12-601C, November 27, 2012.) Can anyone tell me if any other Agencies use these 2 separate plans? From what I have seen, other Agencies seem to use the terms "subcontracting" and "participation" interchangeably. Thanks (I am new to this, so any insights or references are welcome.)
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