Subcontractors can perform work under 8(a) contracts, but certain limitations apply regarding the percentage of personnel costs that these firms may incur under service, supply, and construction contracts. For example, for service contracts, the 8(a) prime contractor must incur at least 50 percent of the personnel costs with its own employees. In other words, the total personnel costs associated with the employees of the 8(a) prime contractor must be equal to or greater than the total personnel costs associated with the employees of all subcontractors performing work under the service contract. Table 1 identifies how much work the firm awarded the 8(a) contract must perform according to the requirements in the subcontracting limitation clause currently in the FAR and applicable to the contracts reviewed for this report. Procuring agency contracting officers are responsible for monitoring whether 8(a) contractors are in compliance with subcontracting limitations. For all of the agencies in our review, SBA has delegated responsibility for contract administration to the procuring agencies through partnership agreements. Partnership agreements between the agencies and SBA outline the responsibilities of both parties in the 8(a) contracting process. These agreements delegate SBA’s contract administration responsibilities, such as overseeing the contractor’s performance, to the procuring agencies after SBA has accepted the procurement into the 8(a) program. The partnership agreements explicitly address subcontracting limitations in a few ways by requiring the agencies to at the time of the contract award, conduct and document an assessment of the 8(a) firm’s ability to comply with the subcontracting limitations; include monitoring and oversight provisions in all 8(a) contracts to ensure that the contractors comply with the subcontracting limitations; and ensure that 8(a) contractors comply with the subcontracting limitations. SBA, DOD, DHS, and HHS officials responsible for administering the 8(a) program stated that contracting officers are responsible for implementing these requirements. Our past work and the work of others, however, have found that contracting officers generally do not do so. In our April 2006 report, we reviewed 16 contracts awarded to 8(a) firms owned by Alaska Native Corporations and found almost no evidence that agencies were monitoring compliance with subcontracting limitations. Contracting officers we spoke with were generally confused about whose responsibility it was to monitor compliance or were unclear about how to monitor the subcontracting limitation requirements under IDIQ contracts. We recommended that SBA take steps to clearly assign accountability for monitoring compliance. SBA did not state if it agreed or disagreed with our recommendations but, in response, the agency provided training to procurement officials and revised the 8(a) partnership agreements to more clearly delineate responsibility to the procuring agency for the monitoring. SBA also provided training to procuring agencies on the contents of the partnership agreements. Nevertheless, about 6 years later, we reported that of 71 8(a) contracts confirmed to have subcontracting, we found no evidence of regular and systematic monitoring of the subcontracting limitations. Contracting officers were still unclear who was responsible for the monitoring and uncertain about how to conduct the monitoring. In this January 2012 report, we noted that the FAR requires contracting officers to include the subcontracting limitations clause in 8(a) contracts but does not state who is accountable for monitoring compliance with the required percentages. In addition, many contracting officials told us that they did not know how to monitor the percentage of work that is subcontracted, in part, because they did not have visibility into subcontractor costs. Lastly, we found no evidence that the contracting officers were enforcing requirements that 8(a) contractors semi-annually demonstrate compliance with subcontracting limitations under IDIQ contracts, in part, because these requirements were not referenced in the FAR. We recommended that OFPP, in consultation with SBA, take a number of actions, such as amending the FAR to direct contracting officers to document in the contract file the steps they had taken to ensure compliance and to clarify the percentage of work required by an 8(a) participant under IDIQ contracts. OFPP agreed with our recommendations and some actions have been taken to address them. For example, SBA amended its regulations regarding subcontracting limitations under IDIQ contracts, issuing a final rule on October 2, 2013. Prior to this change, the 8(a) participant was to demonstrate semi-annually that it had performed the required amount of work for the combined total of all task or delivery orders at the end of each 6-month period under an IDIQ contract. The amended regulations require the 8(a) firm to demonstrate compliance with the subcontracting limitations after each performance period—e.g., for the base period and any option period thereafter. OFPP and SBA stated that they would address the other recommendations as they developed regulations to comply with the most recent amendments to the Small Business Act. SBA has also found that contracting officers are generally not monitoring compliance with the subcontracting limitations. To address FAR requirements, SBA conducts surveillance reviews each fiscal year at various contracting offices to monitor their compliance with small business policies, statutory requirements, and applicable regulations. As part of these reviews, SBA examines a sample of small business contracts to determine whether the contract files contain evidence that the contracting officer monitored compliance with the subcontracting limitations. According to SBA officials, these reviews generally find that the contracting officers are not taking steps to ensure such compliance. For example, through these reviews, SBA has found that contracting officers were either not including the FAR subcontracting limitations clause in contracts or were not monitoring compliance. SBA has made recommendations to these contracting offices to provide training or issue guidance on the requirement so contracting officers better understand their responsibilities to monitor subcontracting limitations. With two exceptions, the contracting officers we met with generally do not monitor the amount of subcontracted work to ensure 8(a) contractors comply with subcontracting limitations, which is consistent with our past findings. Table 2 shows that contracting officers rarely performed all subcontracting limitations-related responsibilities in their agency’s 8(a) partnership agreements with SBA. As noted in the table, only four contracting officers documented and assessed if the offeror could comply with the subcontracting limitations prior to contract award. These assessments varied from questioning the offeror on how it would comply with the subcontracting limitations to using award evaluation criteria that required the offeror to identify the steps it would take to ensure it was in compliance. As required by the FAR, all of the contracts included the subcontracting limitations clause, which requires the contractor to perform a certain percentage of the work. None of the contracts, however, included a monitoring and oversight provision to require the contractor to demonstrate the percentage of work it performed. Subcontracting limitations were monitored for an HHS and a Navy contract we reviewed. In addition to assessing if these contractors would be able to comply, these two contracting officers required the contractor to regularly provide information on the extent to which work was subcontracted. The contracting officers told us that it was their standard practice to monitor subcontracting for this purpose. We did not find evidence that these limitations were monitored in the other eight contracts. In reviewing these eight contracts, we also did not find sufficient evidence in the contract files to independently determine the extent of work subcontractors completed. The other contracting officers we spoke with stated that they do not monitor the extent of subcontracted work to ensure contractors comply with subcontracting limitations. Contracting officers cited many reasons for not ensuring 8(a) contractors complied with subcontracting limitations. We often found that contracting officers, even one of the two who monitored subcontracting limitations, were not fully aware of what they were required to do under the partnership agreements or were unclear on how to ensure compliance (see table 3). Generally, contracting officers understood that they had some responsibility to monitor compliance with subcontracting limitations, but told us that this responsibility was also shared with CORs, in part, because contracting officers are not always onsite to oversee contractor performance as CORs generally are. CORs associated with the 10 contracts we reviewed, however, stated that contracting officers have not delegated this responsibility to them and they do not take steps to monitor the amount of subcontracted work. In addition, some contracting officers stated that the contractor was responsible for ensuring compliance with subcontracting limitations, in part, because the contract included the limitation on subcontracting FAR clause. For example, one HHS contracting officer stated that the 8(a) contractors he works with understand the amount of work they must perform, should be monitoring the amount of subcontracted work, and should inform the government if subcontractors perform more work than allowed. This contracting officer, however, was not aware if the contractor had performed the required amount of work on the contract we reviewed, and contractor representatives for this contract told us that they were not in compliance with the subcontracting limitations at the time we spoke with them. In several interviews during this review and in prior work, contracting officers told us that they primarily rely on the FAR and their agencies’ policies and guidance to understand what their responsibilities are and how to implement them. While agencies’ policies and guidance may supplement parts of the FAR, the purpose of the FAR is to provide uniform policies and procedures for federal acquisitions, and most agencies must follow these regulations. The FAR requires contracting officers to include the subcontracting limitations clause in any solicitation and contract awarded under the 8(a) program, but it does not address the contracting officers’ responsibilities as outlined in the 8(a) partnership agreements. Three contracting officers told us they were fully aware of the contents of the 8(a) partnership agreements, but had not fully implemented those responsibilities, and only one had taken steps to ensure the contractor was in compliance with subcontracting limitations. Four contracting officers were aware of the partnership agreement generally but were not aware that it required them to include, among other things, a monitoring and oversight provision in the contract. Another contracting officer was completely unaware of the partnership agreement.