Federal Small Business Reporting

tech-ind

Overview

This month Other Than Small Business (OTSB) {also known as a large business (LB)} contractors and subcontractors (those holding a contract or subcontract in excess of $650,000 or $1,500,000 for construction) are required to submit their Individual Subcontract Reports (ISR) and Summary Subcontract Reports (SSR) via the Electronic Subcontract Reporting System (eSRS). For some construction projects this can be a time consuming event given the large number of subcontractors.  My typical client has 30 to 90 subcontractors depending on the size of the project.  On May 21st I authored a piece highlighting Small Business Utilization Monitoring and Reporting requirements.  This post calls into action the tips and techniques covered in that post as 30 September 2013 marked the end of the most recent reporting period.  The ISRs and SSRs are due within 30 days of that date.

Individual Subcontract Plan Reporting

The ISR reporting period is 1 April – 30 September and the project team (or group responsible for managing reporting) should have collected and categorized all of the subcontract awards related to the contract.  It is beneficial to start the reporting process early so it can be broken down into several discreet steps creating a more manageable process reducing interference with regular tasks the project team completes on a daily or weekly basis.  Below is an overview of the basic steps for those reporting on small business to complete:

  • Collect and organize all of the subcontract award data (i.e. business name, award date, and amount) made during the period sorting by business type, OTSB, WOSB, SDVOSB, etc.  This can be accomplished using Excel, Access, certain contract / project management databases, or paper and pencil.
  • Ensure the required self-certifications and HUBZone certifications are collected and reviewed for accuracy.
  • Ensure the correct subcontracting plan goals are entered for the ISR to be submitted.
  • Enter the required data in the eSRS ISR reporting tool.  There are several useful step by step guides with detailed instructions on the eSRS site.  Of note the ISR tool will calculate the participation rate percentages for you, although I prefer to calculate the small business (SB) participation rates prior to beginning the process.
  • If required, enter an appropriate remark explaining why goals have not been met.  Regardless if the goals are or are not being met, the team buying out the subcontracts should keep detailed notes on the bidding for each bid package.  This is very valuable information to use for remarks in the ISR in addition to any future contract work in the same region.

Summary Subcontract Reporting

There are a few differences between the ISR and the SSR in addition to a couple of tips that are worth noting.

  • The SSR is a fiscal year summary of Federal subcontracting activity reported by agency.  The more contracts and agencies a company works with the more complex the process becomes.  A common mistake I see is firms incorrectly totaling all of the ISRs for a particular agency and reporting that number.  ISRs are reports documenting subcontracting activity for the life of a contract.  Using the ISR in this manner will inflate the data in the SSR.
  • SSRs are reported at the agency level which creates one or more confusing aspects of submitting the SSR of “who”  or “where” to send it to from the range of choices available on the drop down menu.  The good thing is most agency personnel are very good at directing reports to the correct destination.
  • Similar to the ISR, there are several guides available on the eSRS site containing detailed instructions.  I recommend using the guides as they are helpful.

DoD Office of Small Business Programs (OSBP) recently updated is policy on SSRs and the Small Disadvantaged Business (SDB) participation report.  Highlights from the notice distributed several weeks ago are included below:

  • Starting in FY 2014 the SSR submission will be submitted once per year matching civilian agency requirements.
  • For FY 2013 reporting, contractors submit their consolidated SSR in eSRS to the Department of Defense (9700) and NOT to the department/agency which administers the majority of their subcontract plans.
  • For FY 2013 contractors should not submit the SDB participation report as they are no longer authorized since 10 U.S.C. 2323 expired.  For further guidance go to: http://www.acq.osd.mil/osbp/sbs/esrs.shtml

Summary:

  • Don’t procrastinate starting the reporting process and make sure time is left to review the data for accuracy and completeness.
  • If you have delegated the responsibility for data entry of the ISR, make sure you review the material before it is submitted.  Any errors will find their way back to you.
  • CEO or Senior VPs are required to sign the SSR, make sure they know the report is being submitted and they are briefed on the contents of the report.  Too often I have seen an electronic signature from the reporting authority used and not back-briefed on the event.
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