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Subcontracting Plan under GSA as newly graduated Small Business


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We have recently graduated from a small business to a large business and a modification was completed to our GSA schedule to include a small business subcontracting plan.  For my reporting do I include previous orders under my GSA schedule contract in the subcontracting report OR do only new orders after the modification date of the incorporation of the subcontracting plan to the GSA schedule apply?

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13 hours ago, EGovCon said:

We have recently graduated from a small business to a large business and a modification was completed to our GSA schedule to include a small business subcontracting plan.  For my reporting do I include previous orders under my GSA schedule contract in the subcontracting report OR do only new orders after the modification date of the incorporation of the subcontracting plan to the GSA schedule apply?

I doubt that you would report subcontracting prior to the requirement for a subcontracting plan or reporting. However this is a question that you should  contact GSA directly to ask, not here on an informal Forum.

You must have dealt with someone at GSA when they modified your contract, correct ??? 

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Hi,

In FAR 19.705-2 Determining the need for a subcontracting plan-- "(f) If a subcontracting plan has been added to the contract due to a modification (see 19.702(a)(1)(iii)) or a size re-representation (see 19.301-2(e)), the subcontracting goals apply from the date of incorporation of the subcontracting plan into the contract..."

 

Hope this helps.

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@EGovCon, based on what looks like an "official" GSA blog site, the plan would only be effective on new orders. You can follow up by contacting as indicated to ensure it applies to your situation .https://buy.gsa.gov/interact/community/6/activity-feed/post/8ab1cd64-028c-444c-a14d-b43cf288771c/Updated_Model_Subcontracting_Plans?utm_medium=email&utm_source=govDelivery 

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On 4/15/2024 at 4:39 PM, EGovCon said:

We have recently graduated from a small business to a large business and a modification was completed to our GSA schedule to include a small business subcontracting plan. 

I don't understand your situation.  You state that you "graduated" to a large business.  Were you an 8(a) participant that graduated from that program?  Is FAR 52.219-28 in your contract?  If it is, were you required by the terms of that clause to recertify your size status?  If you were, what was the basis of the recertification?  Was the requirement to submit a subcontracting plan accomplished by including FAR 52.219-9 in your contract?  Was the effective date of the modification requiring a plan the effective date of your contract or some later date?

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