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Commercial Subcontracting Plans

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Our firm which provides commmercial items wishes to change to the "Commercial SK Plan" vs the individual plans we have been submitting.

However, in reading FAR19.704, I am confused as to frequency of submittal as well as when to submit. My understanding was the commercial plan was to be submitted ONCE per year, at the end of MY FIRM's FY (31 December, 2012), to the CO with the LATEST PoP date.

As I try to understand the FAR, it appears it needs to be submitted TWICE/year AFTER GOV FY and 31 MARCH. Also it needs to be submitted to ALL contracts? The commercial plan was suppose to SIMPLIFY the process. This appears to be the SAME as the Individual plans?!

Any feedback is appreciated.

Thank you!

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You may be confusing submission of the Plan with submission of reports, and you may be thinking that the timing of reporting set forth in FAR 19.704(a)(10) applies to commercial subcontracting plans. It does not.

New Plans are required 30 working days before the end of your FY. A single SSR is required to be submitted within 30 days after the end of the Government’s FY. Nothing is required twice a year under commercial plans. See FAR 19.704(d)(2) and (4) and paragraph (g) of the clause at 52.219-9

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