# Presentation: 428997

**Small Business Subcontracting Program Review**
**Small Business Center **
**Presented by **
**Mr. Phil Varney and Chris Travers **
**January 17, 2007**
** **
**       **
**	****	**

**Notes:**
Two types of Reviews:
Full Program Review 
Follow-up Review 

## <date/time>

## Five Parts to a Subcontract Program Review

- <date/time>

_**Five Parts to a Subcontract Program Review**_
**I. General Information**
**II. Performance Factors**
**III. Administration Factors**
**IV. Supplemental Data Tab**
**V.  Ratings And Recommendations **

**Notes:**
Critical factors: Subcontracting Performance and Program Administration II & III . Compliance with FAR requirements establish the basic requirements for an acceptable program rating.  
Any “no” answer for Parts II and III will REQUIRE a “Corrective Action Plan.

II Performance Factors – SF 294 and 295 Reports

III Review the elements of FAR Clause 52.219-9.

IV The intent of this section is to ensure that the SBLO has adequate authority to implement and administer the program.  

V Identifies the criteria for the overall program rating

## Small Business Subcontracting Program Review

**	**_**PART II**__ __**PERFORMANCE FACTORS**_
**SF 295 Reports **
**	****	**
**Accurate**
**On Time**
**Verifiable**
**Trends**
**Amounts must include both direct awards and an appropriate prorated portion of indirect awards****.**

- <date/time>

** ****	****SF 294 Reports****  **
**On time****	****	****       Accurate**
**Verifiable****	****	****       Trends**
**An appropriate prorated portion of indirect awards if applicable.**
**Remarks Block**
**Failure to submit a Subcontracting Report for each contract requiring one.**

- Small Business Subcontracting Program Review

- PERFORMANCE FACTORS

- PART II

**Notes:**
Remarks section: 
Explanation if performance is below the level necessary to achieve the goals, 
or if goals were not achieved on the final report?  

Is there a CAP?

** ****Review of the Small Business Program **
**   ****1. Covers the 11 Elements of the subcontract plan FAR 52.219-9.**
**    ****Requires in depth analysis of how company is fulfilling these requirements.**

- Small Business Subcontracting Program Review

- Small Business Subcontracting Program Review

- a. Goals expressed in terms of percentage of total planned subcontracting dollars for each small business category in all plans
-  b. Statements of total dollars planned to be subcontracted for each small business category in all plans
-  c. Description of the principal types of supplies and services to be subcontracted _**and**_ an identification of types planned for subcontracting to for each small business category

- ADMINISTRATION FACTORS

- PART III

- Small Business Subcontracting Program Review

- d. Method used to develop subcontracting goals.
- e. Method used to identify small business sources.

- ADMINISTRATION FACTORS

- PART III

**Notes:**
d. How and uses bills of material, past history, past performance and is it according to the plan?

e. The following may be considered. 
Sources from past history, outreach. trade fairs, matchmaking events, minority development councils, internal events, home page 
Directed sources? (who directed: Government/Contractor)?  
Subcontracting source lists used?  Updated and applicable 
PTAC’s used?  	Mentor Protégé program?   

f. Indirect costs & subcontracting dollars allocated on the 295?
   Method used written and adequate?      
Applicable indirect costs and subcontracting dollars 
If applicable Proportionately allocated on the Subcontracting Report for 294? 

- Small Business Subcontracting Program Review

- g. The small business duties of the SBLO.
- h. Efforts to ensure that equitable subcontracting opportunities exist for small businesses.
-  i. Flow down of FAR 52.219-8 for purchases of $550,000, ($1M for construction) with large businesses that require subcontracting plans.

- ADMINISTRATION FACTORS

- PART III

**Notes:**
g. Do the duties flow with the program requirements?  
	A formal SBLO appointment letter on file?

h. Use the SBA SUB-NET for locating and advertising for further subcontracting opportunities?  
	use DoD councils, PTACs,  
	Are purchasing personnel, engineers, etc. involved 
	A web page to encourage small business to support the subcontracting requirements? link to the Office of Secretary of Defense
	Is the company a mentor in a federal/state/local government sponsored mentor-protégé program? 

Contractor flow down the “Utilization of Small Business Concerns” contract clause in all subcontracts

- Small Business Subcontracting Program Review

-  j. Cooperates in studies or surveys and submits periodic reports to determine extent of compliance. Submit Individual and Summary Subcontracting Reports IAW the FAR, and ensure that its subcontractors submit the same.
- k. Source lists (e.g., CCR, Thomas Register, internal vendor lists, etc.) or other data used to identify small businesses.
-  l. Organizations contacted to locate sources that are small businesses.
- m. Method used for maintaining records of purchases over $100,000.

- ADMINISTRATION FACTORS

- PART III

**Notes:**
k. Source lists (e.g., CCR, small business guides) used 

l.  contact {such as PTACs, SBA PCR/CMR. To identify new sources 

m. If small business not solicited does file documentation exist to describe the reasons why not?  
	Examples of file documentation include a company form or correspondence.  
	Verify/review procurement records.  
	How are records verified?  
	Does the contractor use specific forms or checklists to document purchase orders over $100,000?

- Small Business Subcontracting Program Review

-  n. Records maintained to document attendance at small business outreach events.
- o.* *Records maintained to document internal guidance and encouragement to buyers through (A) workshops, seminars, training, etc and (B) monitoring performance to evaluate compliance with program requirements.
- p. Method used, on a contract-by-contract basis, to record support award data, including the name, address, and business size of each subcontractor.

- ADMINISTRATION FACTORS

- PART III

**Notes:**
n. Trade + business associations, conferences, and Veteran service    
     Log - outreach events attended by the SBLO and/or other
o Records for internal training, guidance and encouragement
        Who monitors?  How  conducted, web-or classroom;  Who attends?
        What is included: company policies, procedures, employee process ownership, program responsibilities, company initiatives, program changes, and subcontracting performance.  

p. PO’s - name, address, and size of each company
    Copies of CCR/ Certs and reps current in P.O. files 
    How often request new Certs and reps ?  
    Size self-cert contains penalty clause for false representation?  
    Method used to validate SDB and HUBZone certified contractors.  
    No other certifications, other than CCR verification or signed SBA letters, may be utilized      Dept. of Transportation or state certifications are NOT acceptable as certification.)

- Small Business Subcontracting Program Review

- q. Method used to assist small businesses by arranging solicitations, time for the preparation of bids, quantities, specifications, and delivery schedules.
- r.* *Method used to provide adequate and timely consideration of small businesses in all “make-or-buy” decisions.
- s. Method used to counsel and discuss subcontracting opportunities with small businesses.

- ADMINISTRATION FACTORS

- PART III

**Notes:**
r. Do the procurement procedures include adequate and timely consideration for their “make-or-buy” decisions?  
      Is SBLO involved in the “make-or-buy” decision process? 

s. Discuss and counsel small business concerns regarding business opportunities?  
    Have these sessions been successful?

- t. Method used to provide notice to subcontractors concerning penalties and remedies for misrepresentations of business status as a small business for the purpose of obtaining a subcontract.
- u. Method used to ensure the timely payment of subcontractors.
- v. Adequately addressed all previous Corrective Action Plans Including other corrective actions not requiring a formal Action Plan.

- Small Business Subcontracting Program Review

- ADMINISTRATION FACTORS

- PART III

**Notes:**
" It is the policy of the United States that its prime contractors establish procedures to ensure the timely payment of amounts due pursuant to the terms of their subcontracts with small business, veteran-owned small business, service-disabled veteran-owned small business, HUBZone small business, small disadvantaged business, and women-owned small business concerns".

- Small Business Subcontracting Program Review

**2. Record Keeping**
- 	a. Review representative sample of purchase orders of $100,000 or more awarded to Large Business, including purchase orders over $550,000.
-  	b.   Identify any active contracts over $500,000 that contain an incentive fee clause.

- ADMINISTRATION FACTORS

- PART III

**Notes:**
review purchase orders for noted trends or deficiencies.

 A sample of 10% Purchase Orders is suggested, but no less than 20 should be reviewed. If there are fewer than 20, then review all orders.  

_**PART IV – SUPPLEMENTAL DATA**_
- 	**Ensure that the SBLO has adequate authority to effectively implement and administer the program.   Requires in depth analysis of how company is fulfilling these requirements.**

- Small Business Subcontracting Program Review

- Small Business Subcontracting Program Review

- 	Issued by _current_ senior management and disseminated throughout the company.
- 	**2. SBLO Appointment/Authority/Placement in the organization.**
- Formal appointment by senior level management
- Duties and responsibilities defined
- Appointed at appropriate level and who reports to
- Corporate or Division level & Organization chart

- SUPPLEMENTAL DATA

- PART IV

**Notes:**
policy statement: 
       approved and signed by current senior management? 
       disseminated ? if so, how 
(intranet, policies/procedures, staff meetings, training sessions, etc.)?  
Policy statement should reflect top level management's commitment to maximizing opportunities 
Policy statement indicate that the Program is company wide and may be a responsibility of all company departments? 

- Small Business Subcontracting Program Review

*	*

- SUPPLEMENTAL DATA

- PART IV

- Small Business Subcontracting Program Review

**	****3.  Monitoring SB program performance and requirements**.
- 		Management and staff briefed regularly on program.

- SUPPLEMENTAL DATA

- PART IV

**Notes:**
Provide evidence of self-assessment, corrective actions, and other tools used for addressing deficiencies.

- Small Business Subcontracting Program Review

**4. Supplemental Information:**
- 	Strategic sourcing teams, or other groups within the company.
- 	Subcontracting opportunities, normally awarded to a large business now given to Small.
- 	Procurement actions reserved for small business.

- SUPPLEMENTAL DATA

- PART IV

- Small Business Subcontracting Program Review

- 	Corporate, Long Term and Blanket Purchase Agreements, and how they may affect small business subcontracting dollars
- 	Credit card purchases
- 	Internet to advertise procurement requirements

- SUPPLEMENTAL DATA

- PART IV

- Small Business Subcontracting Program Review

- 	Initiatives to ensure more small businesses are able to
-          compete for more “high-tech” procurements.
- Monitor subcontracting goals/plan and readjusts its internal focus on goals that may not be attained.
- Procurement actions addressed specifically within the subcontracting plan, that had to be redirected to another business size category.

- SUPPLEMENTAL DATA

- PART IV

- Small Business Subcontracting Program Review

_**PART V – RATINGS AND RECOMMENDATIONS**_
**Criteria for the contractor’s overall program rating DCMA/SBA MOU May 9, 2003.**

- Small Business Subcontracting Program Review

**Exceeded at least 1 goal and met all of the others on each contract.**
**Exceptional success in assisting, promoting and utilizing small business.**** **
**Outstanding rating signifies that the company has an exemplary program that could be used as a model by other contractors in similar industries.**

- RATINGS

- PART V

**Notes:**
Footnotes:
Examples of such initiatives include, but are not limited to,
   Mentor-Protégé program, 
    Compliance reviews at subcontractors’ sites, 
     A buyer incentive program, 
     Participating in trade fairs, 
     Promoting + Assisting registration in the CCR, 	
     Encourage suppliers to get SDB and HUBZone certification.

- Small Business Subcontracting Program Review

**Highly Successful **
- 	**Met all traditional goals and at least one of the new goals for each contract.**
**  **
**	****Success with initiatives to assist, promote and utilize small business.**
**	****Goes above and beyond the required elements of the program and can provide documentation to support.****	**

- RATINGS

- PART V

- Small Business Subcontracting Program Review

**Acceptable**
- 	**Good-faith effort to meet all goals, but has not met criteria for Highly Successful or Outstanding.  **
**	****Fulfills the requirements of subcontracting plan(s) and the regulations.  **
**	****Individual and Summary Subcontracting reports completed accurately and timely. **

- RATINGS

- PART V

- Small Business Subcontracting Program Review

**Marginal** **-** **Deficient in meeting key plan elements**
- 	**Subcontracting and/or Summary reports are not correct and /or fails to satisfy requirements of a corrective action plan. **
**        ****A corrective action plan is required**
**   *******_**However**_**, management shows interest in bringing its program to an acceptable level and has demonstrated a commitment to do so. **

- RATINGS

- PART V

- Small Business Subcontracting Program Review

**Unsatisfactory – ****Noncompliant with the contractual requirements of DFARS and FAR **
**	****Management shows little interest in bringing its program to an acceptable level or is uncooperative. **
**	****A corrective action plan is required, and the Administrative Contracting Officer(s) shall be notified****.**

- RATINGS

- PART V

**Notes:**
For example, suggested recommendations made by SBA or DCMA on previous reviews have never been implemented.

- Small Business Subcontracting Program Review

_**Risk Rating**_

- RATINGS

- PART V

- Small Business Subcontracting Program Review

**High Risk - Not meeting contract negotiated and DoD goals. **
**Moderate Risk - Meeting contract negotiated but not DoD goals. **
**Low Risk - Meeting contract negotiated and DoD goals. **

- RATINGS

- PART V

- Small Business Subcontracting Program Review

- Summarize and justify the overall program rating.
- All program deficiencies, initiatives, and other areas of note documented within the report and summarized within this section.

- RATINGS

- PART V