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how often should a contractor ask subcontractors to certify their size for Part 19.7

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Why do so many prime contractors make subcontractors notify prime if subKtrs's size changes, either before the prime submits its proposal or during the life of the contract?

For the Small Business Subcontracting Program, a subcontractor has to certify its size "at the time it submits its offer as a section 8(d) subcontractor."

(SBA regs ? 121.411 (a), quoted in full below.)

That could be well in advance of the contractor's submitting its own proposal. There is also no requirement in that reg for the prime contractor ever to ask for a recertification. So why don't primes just ask for the certification with the subcontractor's proposal, or even teaming agreement, then leave it alone?

Is there a requirement somewhere else that primes check on subs before counting them against their goals in their eSRS reports? I don't see such a requirement in the eSRS instructions.

SBA regs: ? 121.411 What are the size procedures for SBA's Section 8(d) Subcontracting Program?

(a) Prime contractors may rely on the information contained in the Central Contractor Registration (CCR), or equivalent data base maintained or sanctioned by SBA, as an accurate representation of a concern's size and ownership characteristics for purposes of maintaining a small business source list. Even though a concern is on a small business source list, it must still qualify and self-certify as a small business at the time it submits its offer as a section 8(d) subcontractor.

(:o Upon determination of the successful subcontract offeror for a competitive subcontract, but prior to award, the prime contractor must inform each unsuccessful subcontract offeror in writing of the name and location of the apparent successful offeror.

© The self-certification of a concern subcontracting or proposing to subcontract under section 8(d) of the Small Business Act may be protested by the contracting officer, the prime contractor, the appropriate SBA official or any other interested party.

[61 FR 3286, Jan. 31, 1996, as amended at 69 FR 29205, May 21, 2004]

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Well, contractor100, perhaps it is because some companies flow down 52.204-8 (Annual Representation and Certifications) to all of their subcontractors, even though it is not required.

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