DLA Subcontracting Program Checklist (April 2023)

Purpose: This document describes the contracting officer’s responsibilities related to FAR Subpart 19.7, “The Small Business 

 Subcontracting Program,” for contracts that require a small business subcontracting plan. Your contracting activity’s small business

 office can offer support or provide guidance to assist you in completing most of these actions. Contracting personnel should also 

 take Defense Acquisition University CLC059, “Management of Subcontracting Compliance”.

When do the requirements/responsibilities in this checklist apply? 

 A subcontracting plan is required (and this checklist is applicable) for contracts that are expected to exceed $750,000 ($1.5 million for construction) or when 

a modification causes the value of a contract without a subcontracting plan to exceed $750,000. A subcontracting plan is not required (and this checklist is not 

applicable) when using a small business set-aside or a set aside under one of the small business socioeconomic programs, for personal services contracts, for 

contracts performed entirely outside of the United States, or if the contract provides no subcontracting opportunities, which is rare. 

 If you determine that the prime contract provides no subcontracting opportunities, your determination must include detailed rationale and be approved at a 

level above the contracting officer (refer to FAR 19.702 & 19.705-2). When a contract requires a small business subcontracting plan, the contracting officer 

must coordinate the proposed plan with the Small Business Administration's procurement center representative and with the DLA small business office prior to 

making an award (DLAD 19.705-4).

Important note about documentation.

 This checklist is a resource to help contracting officers follow the rules and complete the actions associated with the small business subcontracting program. 

Although use of the checklist is discretionary, its use and inclusion in the contract file is a best practice because it supports the responsibilities described in FAR 

Subpart 4.8, “Government Contract Files.” Whether or not this checklist is used, contracting officers must ensure documentation in the contract file is sufficient 

to support rationale for decisions made and actions taken throughout the acquisition process, as well as to document and demonstrate conformance with 

procurement rules and regulations, including those described in this document.

Use “x”

in this 

column 

to mark 

complete

Preparing the solicitation.

For more information 

refer to FAR, 

DFARS, or DLAD...

 Insert the clause 52.219-8, “Utilization of Small Business Concerns.” FAR 19.708(a)

 Insert the clause 52.219-9, “Small Business Subcontracting Plan,” or the clause with its Alternate I, II, III, or IV. FAR 19.708(b)(1)

 Insert the clause 52.219-16, “Liquidated Damages-Subcontracting Plan.” FAR 19.708(b)(2)

 Insert the clause 252.219-7003, “Small Business Subcontracting Plan (DoD Contracts),” or the 

clause with its Alternate I or II.

DFARS 219.708 

(b)(1)(A)
DLA Subcontracting Program Checklist (April 2023)

 Consider incentivizing performance related to the subcontracting plan, including use of the clause 52.219-10, 

“Incentive Subcontracting Program.” FAR 19.708(c)

 For best value source selections, include an evaluation factor or subfactor in the solicitation to incentivize the prime 

contractor’s utilization of small businesses in its performance of the contract. The factor should consider the extent of 

proposed participation by small businesses -- usually as subcontractors -- during the source selection. Note that this is 

a mandatory DFARS requirement, except when using a lowest price technically acceptable source selection process. 

 

 See PGI 215.304(c)(i)(A) for examples of evaluation factors and note that this is different from the requirement for 

the vendor to submit a subcontracting plan.

DFARS 215.304(c)(i)

 Provide the SBA’s procurement center representative (PCR) an opportunity and a reasonable amount of time to 

review the solicitation and to submit recommendations to the contracting officer. Note that FAR 19.705-3 says we 

must allow the PCR to review any solicitation requiring submission of a subcontracting plan before it is issued, but an 

agreement between the contracting activity and PCR may provide a more specific threshold. As a best practice, you 

should coordinate with the PCR through your local small business office and should generally allow at least 5 working 

days for this review.

 FAR 19.705-3

 Check “Yes” in block 13 of the DD 2579, “Small Business Coordination Record,” to indicate a subcontracting plan 

is required. Coordinate the DD 2579 with your contracting activity’s small business office and the PCR, when 

applicable. Be cognizant of any local processes (i.e., particular to the contacting office or MSC) that may pertain to 

the DD 2579.

DFARS 

219.201(c)(10)(B) and 

PGI 253.219-70

Note: in certain scenarios, we may have contemplated that requirements for a subcontracting plan apply, but later we determine that they do not. For example –

- We may have issued our solicitation for an unrestricted procurement (i.e., not a small business set-aside), but the apparently successful offeror is a small 

business despite the acquisition not being set aside. Since subcontracting plans are not required when the prime contractor is a small business, the pre- and 

post-award sections of this checklist do not apply in cases like this.

- Consider the case where the contracting officer anticipates that a subcontracting plan is required and takes the appropriate steps in preparing the 

solicitation. We could learn later (for example, after reviewing the offers we received) that there are no subcontracting opportunities. If you decide at this 

stage that the prime contract provides no subcontracting opportunities, you must prepare a determination (refer to FAR 19.705-2 (c)) and have it approved 

at a level above the contracting officer. In these cases, the contracting officer must update the DD 2579 and coordinate the change with the contracting 

activity’s small business office and the PCR. You must also remove certain clauses from the final contract, such as 52.219-9.

Preaward.

 If not provided with its proposal, require the apparently successful offeror to submit a subcontracting plan. Refer to 

Table 1 for a description of the different types of Small Business Subcontracting Plans. FAR 19.702

 Consider the contractor’s compliance with its subcontracting plans on previous contracts as a factor in determining 

responsibility. For example, past performance information might be available as part of the vendor’s proposal or in the 

Contractor Performance Assessment Reporting System (CPARS).

FAR 9.104-1(c), 9.104-

3(b), 19.705-5(a)(1), & 

FAR 42.1501(a)(5)
DLA Subcontracting Program Checklist (April 2023)

 Review the subcontracting plan for adequacy, ensuring that the required information, goals, and assurances are 

included. The checklist described in DFARS PGI 219.705-4 was created by DoD to assist you with your review. FAR 19.705-4

 Challenge any subcontracting plan that does not contain positive goals and scrutinize the contractor’s rationale.

Before accepting it, obtain approval one level above the contracting officer whenever the subcontracting plan includes 

a small disadvantaged business goal of less than five percent (this does not apply to comprehensive subcontracting 

plans, which are negotiated by DCMA).

DFARS 219.705-4(d)(i)

 Notify the contracting activity’s small business office of the opportunity to review the proposed subcontracting plan 

and provide a reasonable amount of time to review the material and make recommendations. You should also consider 

coordinating with the small business office at the cognizant administration office (e.g., DCMA).

FAR 19.201(c)(17) & 

19.705-4(d)(7) and 

DLAD 19.705-4(e)

 Notify the PCR of the opportunity to review the proposed contract (including the subcontracting plan and 

supporting documentation) and provide a reasonable amount of time to review the material and submit 

recommendations to the contracting officer. As a best practice, you should coordinate with the PCR through 

your local small business office and should generally allow at least 5 working days for this review.

FAR 19.705-4(d)(7) & 

19.705-5(a)(3) and 

DLAD 19.705-4(e)

 Incorporate the subcontracting plan as a material part of the contract. FAR 19.705-5(a)(5)

 For awards to contractors with comprehensive subcontracting plans, insert/substitute/delete clauses, as 

described in DFARS 219.708(b)(1)(B).

DFARS 

219.708(b)(1)(B)

Postaward.

 Take special care to properly code the “Subcontracting Plan” block of the Contract Action Report (CAR) entered in 

the Federal Procurement Data System – Next Generation (FPDS-NG). This block specifies if the contract required a 

subcontracting plan and if it is miscoded the contractor will not be able to submit reports in the Electronic 

Subcontracting Reporting System (eSRS). For example, use code “F” for Individual Subcontract Plan, “G” for 

Commercial Subcontracting Plan or “H” for Comprehensive Subcontracting Plan.

FAR 4.604(b)

 Provide SBA, including the SBA Area Director and the PCR, a copy of the contract and subcontracting plan. As a 

best practice, you should coordinate with the PCR through your local small business office. FAR 19.705-6(a)-(c)

 Include a copy of the subcontracting plan with other contract documents you upload to Electronic Document 

Access (EDA) or other records management platforms to ensure that it is accessible with the rest on the contract. DFARS 204.270-1

 If contract administration is delegated, forward a copy of the plan, or a determination that there is no requirement 

for a subcontracting plan, to the cognizant administration office (e.g., DCMA).

FAR 19.705-6(e) and

DLAD 7.102-90(c)

 Ensure that you have an active eSRS account and that you can login. Contracting officers must have the 

“Contracting Official” role within eSRS so that they can review and accept or reject Individual Subcontract Reports 

(ISRs) and Summary Subcontract Reports (SSRs) in eSRS, which is how the prime contractor reports performance 

against the goals in its subcontracting plan. As part of the eSRS registration, you should choose DLA and then drill 

down to your specific office.

FAR 19.704(a)(10)(iv)
DLA Subcontracting Program Checklist (April 2023)

 Monitor the contractor’s submission of its reports in eSRS, which are due within 30 days of the reporting period 

end date (reports are generally due twice a year by October 30 and April 30). Take appropriate enforcement action if 

reports are not submitted when they are due. Refer to Table 2 for due dates and for guidance on which reports you are 

responsible for.

FAR 19.705-6(f)(1)

 Review Individual Subcontract Reports (ISRs), and where applicable, Summary Subcontract Report (SSRs), in 

eSRS by June 15 or December 15, as applicable. Refer to Table 2 for the dates when your action is due. 

 

 DLA’s contracting officer is responsible for “acknowledging receipt” or “rejecting” ISRs submitted under an 

Individual Subcontracting Plan, even if contract administration has been delegated to another organization, such as 

DCMA. The contracting officer that approved a Commercial Plan is responsible for SSRs submitted for that plan. 

 

 You should reject reports that are not adequately complete, for instance, if there are errors, omissions, incomplete 

data, or if goals included in the report do not match the goals from the approved plan. Failure to meet the goals of the 

subcontracting plan is not a valid reason for rejecting the report and your acknowledging receipt does not mean that 

you approve of or are satisfied with the contractor’s performance. 

 

 DoD has published guides for reviewing ISRs and SSRs and you should refer to them for assistance.

FAR 19.705-6(f)(2) &

(3) and PGI 219.705-6

 Evaluate the prime contractor's compliance with its subcontracting plan, which includes assessing whether the 

contractor has made or is making a good faith effort to comply with the plan and, when applicable, assessing the 

contractor’s explanation concerning its failure to use small businesses in the same scope, amount, and quality 

described in the plan. Take action, as appropriate, to encourage improvement in the prime contractor’s performance 

against its subcontracting plan and goals, when applicable.

FAR 19.705-6(g) and 

DFARS 219.704(1)

 Assess the prime contractor’s performance against, and efforts to achieve, the goals identified in its subcontracting 

plan. Include this assessment as part of your past performance evaluation in the Contractor Performance Assessment 

Reporting System (CPARS).

FAR 42.1502(g) & 

42.1503(b)(2)(v) and 

DFARS 242.1502(g)

 If the contractor failed to make a good faith effort to comply with its subcontracting plan, consider assessing 

liquidated damages.

FAR 19.705-7(b) & 

19.705-7(2)(e)
DLA Subcontracting Program Checklist (April 2023)

Table 1: Types of Subcontracting Plans

Individual Commercial DoD Comprehensive

• 1 contract = 1 plan

• Goals support planned 

subcontracting for 1 contract

• Covers entire contract period 

(including options)

• Contains mandatory elements

• Contracting officer negotiates goals 

and challenges any plan that does not 

contain positive goals

• Preferred for contractors furnishing 

commercial items

• Applies to entire production of 

commercial items sold by either entire 

company or a portion thereof (division, 

plant or product line)

• Based on contractor’s fiscal year

• Annual plan (applies to all Federal

contracts in effect during that period)

• Contains mandatory elements

• Plan should identify the awarded 

contract subject to the plan (contract 

with latest completion date)

• DoD Test Program for 

Negotiation of Comprehensive 

Subcontracting Plans

• Similar to a commercial plan

• May be on a plant, division or

corporate basis

• Annual plan (applies to DoD 

contracts in effect during period)

• Only DCMA has authority to 

negotiate plan & perform surveillance 

review functions (with input from 

Defense Agencies)

Reporting Requirements*

• ISR (semiannually)

• SSR (annually)

• SSR (annually)

• ISR not required

• SSR (semiannually)

• ISR not required

* ISR – Individual Subcontract Report

 SSR – Summary Subcontract Report
DLA Subcontracting Program Checklist (April 2023)

Table 2: Required Subcontract Reports and Due Dates

Type 

Report

Type of 

Subcontracting 

Plan

Report Due 

from the 

Contractor by -

Person responsible for review and 

action on the report in eSRS

Action due for 

contracting officer 

or agency by -

Individual 

Subcontract 

Report

(ISR)

Individual

Apr 30, Oct 30 and 

within 30 days of 

contract completion

DLA’s contracting officer

(even if contract administration has been delegated 

to another organization, such as DCMA)

Jun 15 and Dec 15

Commercial Not required Not required Not required

Comprehensive Not required Not required Not required

Summary 

Subcontract 

Report

(SSR) 

Individual Oct 30 SSR Review Team (i.e., DoD/DCMA) Dec 15

Commercial Oct 30 The contracting officer that approved the 

Commercial Plan Dec 15

Comprehensive Apr 30 and Oct 30 DCMA Jun 15 and Dec 15