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Revising small business subcontracting plans

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We submitted a small business plan under an IDIQ soliciation. The plan was accepted at time of award, and it listed all of our proposed subs., their size and NAICS. The Agency provides disaster relief so in order to reduce bureaucracy, a blanket statement was added to the IDIQ that no new subs need to be be consented to unless they exceed $500k. A waiver is provided for consent in other words. However, it seems we are being requested to revise our small business sub plan every time we propose a new sub. at the task order level. How often can we add subs and revise small business plans under an IDIQ?? Because the nature of work is unknown, we identify new small business subs across the country all the time (in order to meet our goals). It would seem to me that revisions of plans (to add subs--not revise goals), can get rather tedious. I guess as long as the CO is willing to do the revisions, we might as well update the sub plan each time. Is it me or is there something wrong with this picture?

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What type of task orders are allowed under your IDIQ? Did you state what type of subcontracts you would award (T&M, FFP, Cost Plus) or will it vary based on the task order? The CO may be asking to approve new subs over $500K for cost reasonable purposes, not small business participation purposes.

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Is the "small business plan" you are talking about the small business subcontracting plan required by the clause at FAR 52.219-9? If so, I see nothing in that clause that requires you to revise your small business subcontracting plan every time you decide to do business with a new subcontractor.

Could it be that you are talking about "consent to subcontract," as described in FAR clause 52.244-2? Is that clause in your contract? Is there a list of approved subcontractors inserted or attached?

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Yes, a small business subcontracting plan was submitted at time of IDIQ award. Task orders are awarded in various types/structures ( CPFF, FFP, etc but mainly FFP of late). There is a list of the approved subcontractors in the IDIQ which matches up to the ones listed in the small business sub. plan. Because we have an approved purchasing system, it also states prime has been granted a waiver of the requirement of subcontractor consent for subcontract amounts of $500,000 and below based on their approved Government purchasing system. So, if we propose a new subcontractor at the task order level, and if the proposed sub is under $500k in value and may be a T&M type, the contracts folks go to the small business plan, to determine if the subcontractor is listed in the plan, and will request us to modify the small business plan to add the new proposed sub. It seems to us, there is way too much control/focus on the small business sub. plan. Afterall, it is only a plan as to how we will meet goals. And since there is a waiver for consent, there still seems to be some sort of "control" factor at play. I know this Agency is trying to be competent but it may take awhile even with new KOs coming in for places such as DoD with hopefully a fresh perspective.

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Well, you are stuck with it. Small business subcontracting and consent to subcontract are two different matters. Your customer has conflated the two by asking you to amend the subcontracting plan every time you add a subcontractor. We've only heard your side of this, but I suspect that neither they nor the person who signed the contract for your company knew what they were doing. Alternatively, they knew exactly what they were doing but didn't explain it to you.

Either way, you'd better get to work revising the small business subcontracting plan.

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