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sdobro

Subcontracting small business credit for Funding or Procuring Agency?

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I am trying to confirm who gets credit for the subcontracting goaling achievements on contracts - the funding or the procuring agency. In FPDS it is spelled out that the funding agency receives the socioeconomic credit for the prime contract small business award. I do not see similar documentation in eSRS.gov, nor in the SBA scorecard methodology. Does anyone know of any official policy documentation that confirms that the funding agency receives the subcontracting credit?

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I believe the procuring agency currently gets subcontracting credit but SBA is trying to change this….

As quoted from 76 FR 61626 of October 5, 2011 https://www.federalregister.gov/articles/2011/10/05/2011-25767/small-business-subcontracting

“SBA is also proposing to address subcontracting plans in connection with Multi-Agency, Federal Supply Schedule, Multiple Award Schedule and Government-wide Acquisition IDIQ contracts. Funding agencies have expressed interest in receiving credit towards their subcontracting goals for orders placed against another agency's task or delivery order contract. SBA is proposing that the contracting officer for the IDIQ contract will establish subcontracting plans for contractors without commercial plans. The contractor will report small business subcontracting achievement on an order-by-order basis to the contracting officer for the contracting agency. Contractors are currently reporting information on all orders collectively on a semi-annual or annual basis. Reporting on an order-by-order basis will allow the funding agency to receive credit towards its small business subcontracting goals. SBA is requesting comments on whether the reporting requirement should apply to all orders, or only apply to orders above a certain threshold. SBA is also proposing to allow the funding agency contracting officer the discretion to establish goals in connection with individual orders.”

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Thanks for your response. I read the proposed rule and it seems to only address subcontracting credit for orders against IDVs. I thought there must be some existing policy on how subcontracting credit is currently applied to definitive contracts - not IDVs/orders, etc. The reports that get submitted to eSRS include the Funding Agency ID so I thought that was a good indication that the funding agency was currently getting the credit but I don't see it spelled out anywhere.

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