# Presentation: 425527

## Department of Veteran Affairs National Acquisition Center

- Small Business Subcontracting Plans and Reports

## Small Business Subcontracting Plans

- Public Law 95-507, The Small Business Act
- “it is the policy of the Government to provide maximum practicable opportunities in its acquisitions to small businesses, small disadvantaged businesses, women-owned businesses, HubZone businesses, and veteran-owned businesses.”

## Small Business Subcontracting Plans

- Application
- Large Business
- Estimated Contract Value is $550,000 or greater
- Applies to all procurements that include Clause 52.219-9, Small Business Subcontracting Plan

## Small Business Subcontracting Plans

- Plan Types
_***Commercial***_ – includes purchases of all commercial products and services.  Annual plans are required for the period of the vendor’s fiscal year.
- Divisional
- Company-wide
_***Individual***_ – includes only purchases of products and services needed to maintain VA contract.  Effective for life of contract.
**Premise of presentation will be implementation of commercial type plan.**

## Small Business Subcontracting Plans

**Recent Changes**
- Reports are due on October 30th of each year
- Report based on Government’s Fiscal Year
- 52.219-9 Small Business Subcontracting Plan (APR 2008)
- Alaska Native Corporation (ANC) and Indian Tribes
- SDB – Federal Register Notice 9/23/08 and 10/3/08

## Small Business Subcontracting Plans

- Categories and _***suggested***_ VA Goals
- Small – 28.7%
- Veteran-Owned – 10%
- Service-disabled – 7%
- Disadvantaged – 5%
- HubZone – 3%
- Women-Owned – 5%

## Small Business Subcontracting Plans

- Major Features
- Plan periods will coincide with vendor’s fiscal year
- Coordinate with current plan period (i.e. less than one year plan or more than one year to ensure follow-on coincides with vendor’s fiscal year)
- Achievement reports for commercial plans due October 30 of each year.
- The reporting will be based on Government’s Fiscal Year.
- e-SRS (electronic subcontracting reporting system)
- www.esrs.gov

## Completing the Subcontracting Plan Form

- Page 1 – Contractor’s Information
- Subcontracting plan period
- Date –submission date, if revision(s) submitted, need to update this date
- Contractor name
- Subsidiaries included
- Contractor corporate address
- Item/Service – identify product or service category (i.e. pharmaceuticals, med/surg)

## Completing the Subcontracting Plan Form

- Page 1 – Percentages
***Small*** business concerns:  % of total planned subcontracting dollars that will be targeted for small business
***Veteran-owned small*** business concerns:  % of total planned subcontracting dollars that will be targeted for veteran-owned business
***Service-disabled veteran-owned small*** business concerns: % of total planned subcontracting dollars that will be targeted for service-disabled veteran-owned business
***Small disadvantaged*** business (SDB) concerns:  % of total planned subcontracting dollars that will be targeted for small disadvantaged business
***Small women-owned*** business concerns:  % of total planned subcontracting dollars that will be targeted for small women-owned business
***HUBZone small*** business concerns:  % of total planned subcontracting dollars that will be targeted for HubZone business

## Completing the Subcontracting Plan Form

*Page 1-2 – Plan Type*
_**Individual**_ – identify associated contract or solicitation number
_**Commercial Division-wide**_ - % of total annual sales – represents proposed subcontracting spend against division’s total annual sales
_**Commercial Company-wide**_ - % of total annual sales – represents proposed subcontracting spend against company’s total annual sales

## Completing the Subcontracting Plan Form

*Page 2 – Associated Dollars*
- Total dollars planned for ***Small*** business concerns
- Total dollars planned for ***Veteran-owned small*** business concerns
- Total dollars planned for ***Service-disabled veteran-owned small*** business concerns
- Total dollars planned for ***Disadvantaged*** ***small*** business concerns
- Total dollars planned for ***Women-owned*** ***small*** business concerns
- Total dollars planned for ***HUBZone small*** business concerns
_***Total dollars planned must correspond to the percentage goals***_

## Completing the Subcontracting Plan Form

*Page 2 – Principal Products/Services*
- (3) List proposed dollars attributed to each product/service category on the chart (if using fillable form, this will populate last page)

## Completing the Subcontracting Plan Form

*Page 3 – General Information*
- (4) Describe method(s) used to develop goals
- (5) Describe method(s) used to identify potential sources (See FAR 52.219-9(d)(5) for examples)
- (6) Describe how indirect and overhead costs were used – this is N/A for commercial plans

## Completing the Subcontracting Plan Form

*Page 4 – General Information*
- (7) Identify plan administrator and provide contact information
- 	Identify plan administrator’s duties related to the management of the plan
- (8) Describe efforts to be taken to ensure equitable opportunity for various small business to compete for subcontracts

## Completing the Subcontracting Plan Form

*Page 6 – Plan Period and Signatures*
- Identify plan period – this should coincide with vendor’s fiscal year and previously approved plan
- Signature, title of signatory, and date

## Completing the Subcontracting Plan Form

*Page 7 – Prior Year Information & Proposed Goals*
***Prior Year/Contract Goals*** – Identify your previous plan’s goals (this information should match your previously approved plan)
***Prior Year/Contract Achievements*** – Identify your actual  accomplishments under your previous plan
- 	(this information should match your e-SRS report)
***Goals Projected for Current Year/Contract*** – reiterate information from pages 1 and 2 of your proposal
- *If you do not have achievements for full period, use estimate and explain methodology, as well as identify timeframe provided.

## Small Business Subcontracting Plans

- Explanation of Challenges (attachment or cover letter)
- Information that can enhance your plan to explain conditions affecting your proposal
- If growth from previous plan is not projected (compare against achievements)
- If experience change to business model affects opportunities
- If goals are affected by controls from within the industry and/or company
- FDA regulatory issues
- ISO requirements
- Market limitations
- Business process requirements

## Small Business Subcontracting Plans

- NAC receives
-  submitted plan

- NAC reviews plan

- Plan acceptable for
- submission to SBA

- Request revisions
- from vendor

- No

-  NAC submits plan
-  to SBA rep

- Yes

- Recommended for
- approval

- Modify contract,
- include with award

- Yes

- Request revisions
- from vendor

- No

## Small Business Subcontracting Plans

- Timelines
- 45-60 days prior to expiration of plan, follow-on plan should be submitted for review and approval
- pro-rate if needed
- Coordination with SBA
- Plan must be approved prior to finalizing contract award or contract extension

## Small Business Subcontracting Plans

- E-SRS (electronic – Subcontract reporting System)
- _[www.esrs.gov](http://www.esrs.gov/)_
- Reports due October 30th of each year
- Report based on Government’s Fiscal Year.
- Submit as Prime Contractor
- Contract office must accept/reject
- % attributable to agency should never be 100%
- Select 3600, Veteran Affairs
- NAICs as listed on contract
- SBA on-line training

## Small Business Subcontracting Plans

- Point of Contact
- Contracting Officer
- Subcontracting plan team
- FSS –Helpdesk: 708-786-7737 or _[helpdesk.ammhinfss@va.gov](mailto:helpdesk.ammhinfss@va.gov)_
- National Contract Service:
- Pharmaceuticals, Teresa Hussain, 708-786-5852
- Other Branches – Assigned Contracting Officer,
-    708-786-5150

## Small Business Subcontracting Plans

- Thank You