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Submission Logistics for Master SB Subcontracting Plan

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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!

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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.

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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.

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I don't know what the SBLO Handbook is, but you need to be careful of terminology. A commercial plan and a master plan are different. See the definitions in FAR 19.701. I don't know what a commercial products plan is.

Maybe the really relevant part is FAR 19.704( d ) instead of ( b )? If you're providing commercial items (services), ( d ) is the right paragraph for a commercial plan instead of ( b ) for a master plan.

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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

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Coming in late here, the first contracting officer where a plan is submitted approves the master plan. It seems like the master plan is almost a corporate policy statement. Then the goals for the individual contract are negotiated. It seems many universities use such plans. An advantage to this is that there is one template for all plans. One would hope the matter would be well done, concise, and with all eleven elements clearly identified. If one is anticipating this before even needing it, one cannot help but wonder if federal smalls are already being cultivated into the supplier base.

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