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ContractSpecialistTJohn

When is a Subcontracting Plan required?

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Good Day All:

I have two questions both of which are related to subcontracting.

  1. I am inquiring about when a subcontracting plan is required. Is it necessary for a subcontracting plan to be included if Offeror is taking credit for other entity's projects (ie. relevant experience project) or will meaningful relationship letters will suffice?
  2. Also for a small business set aside where the small business is the prime contractor what are the requirement for the subcontracting plan?

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You need to separate two different uses of the term...

Are you talking about a subcontracting plan such as described by the contract clause at FAR 52.219-9, Small Business Subcontracting Plan, which will be enforced after contract award? A small business prime contractor NEVER has to submit a subcontracting plan, even if the clause included in the prime contract.

Or are you talking about a subcontracting plan (a poor choice of words) to support an acquisition in the pre-award stage where subcontracting is one of the evaluation factors to select the eventual awardee?

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In an IDIQ contract with multiple pools, although small businesses are not required to submit subcontracting plan, they have the option to include a subcontractors so that they may compete in a pool where they may not meet the qualifications without a subcontractor. Does this answer the question?

What terminology would you suggest to define the above situation?

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A small business prime contractor can have subcontractors without a subcontracting plan.

I am supposing you are talkiing about a pre-award situation where you are competing for a task order and the solicitation requires a "subcontracting plan" for the competitive evaluation of offerors as part of the process that will be used to select the task order awardee. Is that right?

If so, the "subcontracting plan" you are being asked to submit is not a subcontracting plan as that term is defined anywhere in the FAR or in the contract clause at FAR 52.219-9. Rather, you are being asked to submit information for the evaluation of competitive offers, and the Government is somehow evaluating the subcontracting approach along with price and maybe other factors. If you want to play in the competition, you need to submit a proposal that gives the Government evaluators what they asked for in the solicitation.

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In my experience such a plan would describe the responsibilities of the prime and each sub as they relate to each other, the distribution of work, the lines of authority (bearing in mind that the prime must be "in charge"), perhaps a past working relationships among the prime and the sub(s), the qualifications of the subs, the prime's past experience in managing subs, etc. The Government wants to know how the use of the subs will benefit the project, how it would all work smoothly, and if there's any prime/sub management experience or history that would help them be more comfortable that all will run as anticipated.

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TJohn, Are you writing the RFP or responding to it? Is this a solicitation for a new ID/IQ with multiple pools or a request for task order proposals on a existing ID/IQ?

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TJohn, If you are a firm responding to a solicitation for a new IDIQ with multiple pools or to a task order RFP, it would seem that the solicitation would describe what to submit and how it will be evaluated. Rather than asking specific questions from readers who don't have access to the solicitation, if it isn't clear on its face, I highly recommend that you inquire of the organization that issued it.

Considering the expense and resources involved in such competitions, there is risk involved in following general advice here, especially where the audience doesn't know the specific purpose of the submission requirements or how the agency says it will evaluate the information.

If you are preparing the solicitation, please disregard this post.

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