Federal Prime Contractors have unique obligations and requirements when it comes to their supply chains. There are also many opportunities for small businesses as subcontractors.
Federal Subcontracting Plans
Federal contractors that are large businesses (including affiliates) are required to provide an acceptable subcontracting plan before they can receive award of any contract with an estimated dollar value (including base and all options) exceeding $750,000 ($1.5 million for construction). The subcontracting plan must include specific dollar and percent goals for subcontracting to small, HUBZone, small disadvantaged, small women-owned, veteran-owned small, and service-disabled veteran-owned small business firms. There are different types of subcontracting plans. A commercial subcontracting plan is the preferred type of plan for contractors furnishing commercial items. This type of plan covers the contractor’s entire production of commercial items sold during its fiscal year and is negotiated annually. An individual subcontracting plan only applies to a specific contract and covers the period of performance for that contract.
An ostensible subcontractor is a subcontractor that performs the primary and vital requirements of a contract, or a subcontractor upon which the prime contractor is unusually reliant. A prime contractor and it’s ostensible subcontractor will be treated as affiliates, or joint venturers, for size determinations and other determinations on qualification for a particular set-aside procurement. This treatment is designed to prevent “false front” or “improper pass-thru” situations where, on paper, a business that does not qualify for the set-aside is a subcontractor to a qualifying small business prime, but in reality the non-qualifying subcontractor performs the primary and vital parts of the contract and/or the prime is extremely dependent on the non-qualifying subcontractor.
SubNet is the Small Business Administration’s (SBA) Subcontracting Network System that bridges the gap between businesses seeking small business subcontractors and small businesses seeking subcontracting opportunities. SubNet does this by facilitating the matching of large businesses with small businesses. SubNet allows any firm to post and small businesses to search solicitations, notices of sources sought, and outreach events for small business participation.
SubNet’s purpose is to be the centralized system for all federal government small business subcontracting opportunities by providing a no-cost system to post or search small business opportunities that is available 24 hours a day/7 days a week, at www.sba.gov. SubNet is the system small businesses utilize to identify federal government subcontracting opportunities.
The Business Directory in SubNet is a listing of businesses in a specific area, to which small businesses can market their products and services. This directory assists small businesses by providing information that allows them to connect with contractors in their industry.
Electronic Subcontracting Reporting System (ESRS)
The electronic Subcontracting Reporting System (ESRS) http://www.esrs.gov/ is the official site for reporting federal subcontracting accomplishments.
The Thomas Register of American Manufacturers, traditionally known as the “big green books” and “Thomas Registry”, was a multi-volume directory of industrial product information covering 650,000 distributors, manufacturers and service companies within 67,000-plus industrial categories that is now published on ThomasNet.
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