# Presentation: 911628

## Electronic Subcontracting Reporting System (eSRS) October 25, 2005

## Electronic Subcontracting Reporting System (eSRS)

- The eSRS is an electronic, web-based system for subcontract reporting that will replace the SF-294 & SF-295 paper forms.
- When DoD comes on board in FY 2006, it will be a Government-wide system and the _only_ automated system authorized for subcontract reporting.

## Organizational Structure

_***Systems Steward***_
- U.S. Small Business Administration (SBA)
_***Contractor***_
- Symplicity Corporation, Inc.                              8(a) firm based in Arlington, Virginia

## System Features (cont.)

***	***_***Critical Systemic Linkages***_
- Central Contractor Registration  (CCR)
- Federal Procurement Data System (FPDS-NG)
- Government-wide agency hierarchy
- DUNS numbers for prime contractors and subcontractors

## IAE Architecture

**Notes:**
This diagram depicts the relationships between the agency systems on the left and the various IAE services in the gray boxes.  It also shows the many other systems that IAE interfaces with to validate data or collect data

## Electronic Subcontract Reporting System (eSRS)

- The eSRS is a _downstream_ FPDS/NG application –
- _On the Positive Side_: If a contract contains a subcontracting plan and has been entered correctly in FPDS/NG, the eSRS automatically receives a record of it;
- _The Downside_: If a contract is _not_ in in FPDS/NG or has _not_ been entered correctly, the contractor won’t be able to enter his ISR (formerly the SF-294) report at all

## System Features

_***Business Processes***_
- Identifies contracts in FPDS-NG having subcontracting requirements
- Automates completion and submission of SF-294 and SF-295
- Will include the Annual SDB Breakout Report (3-digit NAICS subsector)
- When fully operational, it will also automate the Optional Form 312

##   Goal Computation on the ISR

- The system calculates the achievements by two methods:
- % of contract value
- % of subcontracting   ___________________________________
- 	_Note_: the eSRS will only calculate the percentage on the _achievement_ side, _not the goal columns_.  This is by intent, because we want the contractor to copy the goals from the subcontracting plan exactly as they appear in the plan.

## System Features (cont.)

- Provides breakout of subcontracting data down to the buying activity level.
- Generates standard and ad hoc reports
- Analysis of Subcontracting Plan Goal Attainment
- Five-Year Trend Table
- SBA Goaling Report for Congress & the President
- Several other standard reports
- Generates automatic reminder notices and delinquent notices.

## Critical Milestones

_***Beta Testing and Acceptance***_
- September 2005
_***Initial Operating Capability (IOC)***_
- Target: week of October 24, 2005
_***Full Operating Capability (FOC)***_
- Target: 8 weeks after IOC

## Who should be using the eSRS?

- As of October 2005: all civilian agencies and nearly all civilian contractors should begin using the eSRS
- _________________________________
- The Electronic Subcontract Reporting Systems developed by NASA, DOE and GSA’s FSS _cannot_ be used for currrent reporting – those three systems will now be folded into the eSRS

## What Should Contractors Enter into the eSRS?

- Except as noted below, all contractors holding contracts with _civilian agencies_ must enter their Summary Reports only (formerly called the SF-295) _for FY 2004_ (the fiscal year ended 9-30-04 – a year ago)
- GSA & NASA contractors that used the GSA & NASA Electronic Subcontract Reporting Systems, respectively, for their FY 2004 reports are exempt from this requirement

## What Should Contractors Enter? (continued)

- All contractors holding contracts with _civilian agencies_ must use the eSRS for both their Individual Contract Reports (ISRs) and Summary Subcontract Reports (SSRs) for the period ended September 30, 2005.
- Contractors may _not_ use the NASA, GSA, DoE, or any other electronic system for the 9-30-05 reports!

## What Should Contractors Enter? (continued)

- Contractors whose contracts are _not_ in FPDS/NG (e.g., FEHBP contractors such as Blue Cross & Blue Shield, contractors holding Medicare contracts, USAID contractors, and contractors with so-called “black contracts”) may have to submit paper reports for now
- Contact SBA Headquarters for guidance on a case-by-case basis

## What Should Contractors Enter? (continued)

- SBA will _not_ require mid-year FY 2005 reports (March 31, 2005)
- Some agencies may ask their contractors to submit these reports anyway;
- the eSRS _does_ have the capability to accept them.

## Do Contractors Have an Extension for Filing?

- SBA has drafted a memorandum for OFPP authorizing a 60-day extension for filing the 9-30-05 reports (60 days from IOC)
- If approved, this would be in line with the previous OFPP memorandum dated March 18, 2005, which authorized a similar extension for the 9-30-04 and 3-31-05 reports

## What About DoD?

- DoD is scheduled to begin using the eSRS during the third quarter of FY 2006 (i.e., for the period ended March 31, 2006)
- DoD contractors should submit paper SF-294s and SF-295s to DoD for the time being

## When will the eSRS be fully operational?

- The Statement of Work requires the contractor to deliver Full Operating Capability (FOC) within 8 weeks of IOC
- This could still be changed by contract modification; the eSRS Team may want to prioritize certain tasks and postpone others

## What will FOC give us that IOC doesn’t?

- FOC will provide an application interface so that contractors with electronic systems of their own can simply upload their data into the eSRS (as opposed to keypunching it into the eSRS one report at a time)

## What will FOC give us that IOC doesn’t? (continued)

- FOC will provide the reports that SBA’s CMRs need (the 5-year trend table and SBA Form 1907 used for Desk Reviews, among other things)
- FOC will also address the unique needs of DoD (e.g., the SSR reports for the comprehensive subcontracting plans)

## Is the FAR being changed?

- SBA is finalizing a FAR case that includes changes to subpart 19.7 and the related clauses, especially 52.219-9
- In the meantime, SBA’s Office of General Counsel has ruled that the eSRS is the electronic equivalent of the SF-294 & SF-295

## FAR Case

- Revises subpart 19.7 and clauses at 52.219-9 & 52.219-25 to replace all references to SF-294, SF-295, and Optional Form 312 with eSRS.
- Revises the flow-down provision at 19.704(a)(9) and 52.219-9(d)(9) to require the prime contractor to flow the _prime contract number_ down to the subcontractors at lower tiers
- prime contract number now becomes a _mandatory field_ in the eSRS, _even for subcontractors_, in order to facilitate lower-tier reporting.

## FAR Case (cont.)

- Moves “General Instructions” from the paper forms to the clause at 52.219-9.
- Requires contractors to print a hard copy of the Summary Report(s) and have them signed by the CEO.
- Contractor will be required to keep hard copy with CEO’s signature on file for 4 years.
- SF-294, SF-295, & Optional Form 312 will all be deleted from Part 53 – i.e., abolished!

## FAR Case

- The Small Business Committee of the FAR Council will review and discuss the specific provisions in the proposal
- The regulation will be issued as a _Proposed Rule_ or _Interim Final Rule_
- 60-day public comment period
- Final Rule will reflect changes resulting from public comments, as appropriate

## How will the eSRS Help Desk work?

- The Help Desk will handle all _technical questions_ regarding the use of the eSRS
- Questions regarding subcontracting policy will be referred to SBA
- Other problems/issues will be forwarded to the Agency Coordinator of the agency that awarded the contract

## REVIEW OF REPORTS

- _Government will review_:
- Prime Individual Subcontracting Report
- All Summary Subcontracting Reports
- _Higher-Tier Subcontractors will review_:
- Lower-Tier Individual Subcontracting 	Reports

## TROUBLESHOOTING

- _CCR ISSUES-_
- CCR Assistance Center 888-227-2423
- _FPDS-NG ISSUES_
- Call the Contracting Officer
- _eSRS ISSUES_
- Contact the eSRS Helpdesk

## Lower Tier Reporting
Full operating capability will include a report showing subcontracting activity at lower tiers (fictitious example on next slide)
This feature will be available only for contractors that submit the Individual Contract Report 
The eSRS FAR case does not propose to change the current rule that prime contractors may not take credit for subcontracts at lower tiers

- Full operating capability will include a report showing subcontracting activity at lower tiers (fictitious example on next slide)
- This feature will be available only for contractors that submit the Individual Contract Report
- The eSRS FAR case does _not_ propose to change the current rule that prime contractors may not take credit for subcontracts at lower tiers

- eSRS Industry Day

## Sample Lower Tier Report

## MARC Meeting in Annapolis 10/25/05

- Thank you for inviting me to speak to you today.
- Please feel free to contact me if I can ever help you in any way.