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ElBarz

Difference between a socio-economic plan and Small Business Subcontracting Plan?

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I am looking for someone's interpretation of the difference between a socio-economic plan and Small Business subcontracting plan?  I understand that the small business subcontracting plan follows FAR 19.7 and after it is submitted with a proposal, it will be incorporated as part of the contract.  The Socio-Economic Plan is submitted as part of a technical proposal but it is not added as an attachment to the awarded contract.  

"The Offer shall provide a socio-economic plan and provide targets, expressed as percentages of total contract value, for small businesses, small disadvantaged businesses, women-owned small businesses, veteran-owned small businesses, service-disabled veteran-owned small businesses, and HUBZone small businesses in any of the North American Industry Classification System (NAICS) Major Groups as determined by the Department of Commerce. The targets may provide for participation by a prime contractor, joint venture partner, teaming arrangement member, or subcontractor. Targets will be incorporated into and become part of any resultant contract."

Is the SE plan simply a regurgitation of the SB Subcontracting Plan since the SB Subcontracting Plan is simply not part of the evaluation criteria?  Or is the SE Plan a deeper dive into the SB Subk Plan - meaning the methodology/approach etc to select the subs?

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The FAR does not mention a socio-economic plan.  My cynical side thinks this is a way for a contracting officer not to do business with a small business since small business subcontracting plans are not required from small business concerns.  Further, with the limitation on subcontracting imposed on small business concerns, they may be constrained on the subcontracting opportunities that exist under a particular contract.

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2 hours ago, ElBarz said:

Is the SE plan simply a regurgitation of the SB Subcontracting Plan since the SB Subcontracting Plan is simply not part of the evaluation criteria?  Or is the SE Plan a deeper dive into the SB Subk Plan - meaning the methodology/approach etc to select the subs?

Seems to be one and the same, but you should check with the contracting officer. If we're right then you can file off the title of your SB plan and call it an SE plan and there you go.

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Looks like the agency cribbed from the now defunct FAR 52.219-24(b):

Quote

In order to receive credit under the source selection factor or subfactor, the offeror must provide, with its offer, targets, expressed as dollars and percentages of total contract value, for SDB participation in any of the North American Industry Classification System (NAICS) Industry Subsectors as determined by the Department of Commerce. The targets may provide for participation by a prime contractor, joint venture partner, teaming arrangement member, or subcontractor; however, the targets for subcontractors must be listed separately.

 

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It might make a difference knowing the Agency that is issuing this. Some Agencies have their own procurement regulations.

 

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This is from the Navy.  The closest thing I could find in my research was a Small Business Participation Program Plan.  Even that doesn't seem to make sense since this is a MAC bid.

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Guest Vern Edwards
On 3/29/2018 at 7:01 AM, ElBarz said:

Is the SE plan simply a regurgitation of the SB Subcontracting Plan since the SB Subcontracting Plan is simply not part of the evaluation criteria?  Or is the SE Plan a deeper dive into the SB Subk Plan - meaning the methodology/approach etc to select the subs?

Ask the contracting officer.

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We already submitted questions and there was no clarification.  Only that they were separate items to submit for the proposal.

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On 3/30/2018 at 6:29 PM, ElBarz said:

We already submitted questions and there was no clarification.  Only that they were separate items to submit for the proposal.

Sounds like you now have your marching orders to comply with the paragraph in question and all other related requirements. I contemplate those to be FAR 52.219-9, DFARS 252.219-7003 and possibly one or more Navy Marine Corp Acquisition Regulations Supplement (NMCARS) clauses. Your post did not indicate which clauses, if any were included in the solicitation terms. There are some differences between those clauses and the so called socio-economic paragraph in question. For example, the socio-economic paragraph appears to be unique in its reference to HUBZone and NAICS. Also it includes an option “for participation by a prime contractor, joint venture partner, teaming arrangement member, or subcontractor.”  Perhaps it means that you may include in your proposed subcontracting plan, targets and goals developed by some of your non-small business subcontractors for their subcontracting. If so, you may wish to obtain such targets and goals from them in their proposals to your company and obtain their permission to use the data to increase your company’s small business plan targets and goals. This would give your company more credit for compliance.

See 13 CFR Part 121 and 125 at https://www.govinfo.gov/content/pkg/FR-2016-12-23/html/2016-30874.htm

  

 

Edited by Neil Roberts
typo

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Is this solicitation for commercial items? 

If so, under the right conditions, a SB subcontracting plan can be company-wide and not specific to the solicitation.   The plan can also be expressed in terms of the percentage of dollars subcontracted vs. some other standard (like the contract value.)   So, when using a company plan, a prime might pull in a $billion annually, subcontract only $200 annually, and have $100 of that $200 go to a small business.   And that small business might mow the lawn one time at their HQ.   In that case, the Company SB Commercial SubK Plan would show 50% attainment...and would be applied to multiple contracts throughout the year.   

If so, the salient points of the new technical requirement is that the dollars be tied to those companies performing on the contract, and that the percentage attainments are tied to the total contract value, not just the value that the prime decides to subcontract.   It seems like a way of beefing up the commercial SB plan requirements by creating a new, higher bar; one that can be evaluated and preference given to a bidder willing to actually involve small subcontractors in the effort, vs. a Company SB Commercial SubK Plan which can only really be a "yes/no" evaluation. 

Does this fit the situation?  

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Might be the difference between using small business as an evaluation factor (FAR Part 15) and the requirement to negotiate an acceptable small business subcontracting plan with the contracting officer for any contract greater than $700,000 that has subcontracting opportunities (FAR Part 19).

You're evaluated on the evaluation factor. It can help you win or lose the contract.

You're required to have the plan. You cannot receive contract award without it. 

Matching the plan to what's promised in the evaluation factor does not always happen. 

Incorporating the plan into the contract to create a contractual obligation does not always happen. 

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