This is a quick reminder for Federal contractors holding a contract that includes a subcontracting plan. This month the mid-year Individual Subcontract Reports (ISRs) are due for large businesses. As with previous reports, ISRs are submitted via the Electronic Subcontract Reporting System (eSRS). You can refer to another article I posted on May 21st 2013, highlighting Small Business Utilization Monitoring and Reporting requirements.
- The ISR reporting period is 1 October 2013 – 31 March 2014 and the project team (or group responsible for managing reporting) should have collected and categorized all of the subcontract awards.
- Collect and organize all of the subcontract award data (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, some contract / project management databases, or paper and pencil.
- Ensure the required self-certification forms, 8(a), and HUBZone certifications are collected and reviewed for accuracy. Self-certifications are acceptable for: Small Businesses, Small Disadvantaged Businesses, Woman Owned Small Businesses, Veteran Owned Small Businesses, and Service Disabled Veteran Owned Small Businesses.
- Ensure the correct subcontracting plan goals are entered into the ISR being submitted.
- Enter the required data in the eSRS ISR reporting tool. There are several useful step by step guides with detailed instructions (http://www.esrs.gov/). 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.
- Even if a contractor did not have any subcontracting activity during the reporting period they are still required to submit a report. See eSRS FAQs for details.
- 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.
- Mid-year Summary Subcontract Reports are not required any longer for DoD.