Small Business Utilization Monitoring and Reporting

In previous posts about small business subcontracting I have discussed activities along the small business planning continuum ranging from outreach efforts to putting a subcontracting plan in to action.  After project award the real work of a small business subcontract plan begins and this activity must be documented semi-annually in the Electronic Subcontract Reporting System (eSRS).  This series ends with an article addressing the monitoring and reporting requirements associated with a typical federal construction project.

Monitoring

Typically the Subcontracting Plan is administered by the Administrative Contracting Officer (ACO) for the government and the Small Business Liaison Officer (SBLO) for the prime contractor.  The ACO is responsible for monitoring, evaluating, and documenting contractor performance on behalf of the award agency.  Therefore, establishing an adequate program to monitor your small business program is important so the program is effectively and efficiently run.  Ultimately the success of a company’s small business program is an integral part of a firm’s business development efforts.  Failure to meet small business goals on federal projects can reflect negatively when responding to future proposals.

Feature of an adequate program:

  • Your company has a published policy letter from the Chief Executive Officer supporting the program.
  • The SBLO maintains documentation of meetings with top management on the status of the program.
  • The SBLO reports directly to senior leadership and depicted on the company organizational chart.
  • The small business policies and procedures are published and distributed to project teams.
  • Individuals directly involved with the program have received training on the small business program and the federal requirements.
  • Self-certification are reviewed, tracked to ISRs and SSRs, and retained for compliance reviews.
  • HUBZone Small Business certifications are verified through the SBA (FAR 52.219-8(d)(2).

Reporting

eSRS Home Page

Reporting small business utilization on federal projects is one of several post-award compliance tasks for large businesses (FAR 52.219-9(d)(10)(iii)).  Reporting is accomplished via eSRS.  Two types of reports are required, the Summary Subcontract Report (SSR) and the Individual Subcontract Report (ISR).

The SSRs collects prime and subcontractors award data for a specific agency during the given fiscal year.  Reporting periods:

For Department of Defense (DoD) and NASA:

  • 1 October – 31 March
  • 1 October – 30 September

For Non DoD agencies:

  • 1 October – 30 September

Reports are due 30 days after the reporting period ends.

The ISR collects prime contractor and subcontractor award data on a project basis over the life of the project.  Unlike SSRs the data carries over each year.  Reporting periods:

  • 1 October – 31 March
  • 1 October – 30 September

Reports are due 30 days after the reporting period ends.

Two common techniques to monitor participation include the use of the spreadsheets or a contract management database program.  Either technique is acceptable; the method used is dependent on which is most compatible with the IT maturity of the firm.  Related to my post on 30 January 2013 “Small Business Outreach and Database Management”, the level of effort in fulfilling the reporting requirements is affected by the capabilities, or lack of, with your contract management or small business utilization tracking tool (spreadsheets).

Reporting Tips:

  • A database can reduce the level of effort to complete the reporting requirements.  For example, Primavera Contract Manager and Prolog can both be modified at the company level to facilitate the reporting process.
  • Develop a consistent methodology to help project teams collect, document, and store self-certifications.  Per 13 CFR 121.411(a), a subcontractor must qualify and self-certify as a small business at the time it submits its offer as a small business subcontractor. Do not retroactively apply small business subcontracting accomplishments. (eSRS Quick Reference Guide)
  • Visit the eSRS website, there are numerous guides, step-by-step samples, and instructional videos to assist with the reporting process.
  • Don’t wait until the last minute to start the reporting process.
  • Throughout the reporting period make sure the project team is collecting information on subcontract awards, self-certifications, and the bid history for each subcontract to document good faith efforts.
  • Review self-certification against System for Award Management (SAM) or the SBA Dynamic Small Business Search (DSBS).  Occasionally small businesses will inadvertently check the incorrect subcategory or miss one entirely.  The effort in due diligence will help the large business and the small business.
  • Under current regulations a self-certification form must be collected for each small business for each project. (SBA SBLO Handbook)

Common trends I find during subcontracting programs reviews for clients:

  • Self-certifications are completed incorrectly resulting in missed or inaccurate small business credit for the prime contractor.
  • The tracking tool used has math errors or small businesses are not categorized according to their self-certification.
  • Summary Subcontract Reports (SSRs) contain more than one fiscal year of data.
  • ISRs are not submitted in a timely manner.
  • ISRs contain insufficient information documenting good faith efforts and are rejected by the Contracting Officer or ACO.
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3 thoughts on “Small Business Utilization Monitoring and Reporting

  1. Pingback: 2014 NDAA Allows Prime Contractors to Count Lower Tier Small Businesses | CWG Associates

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