Individual Subcontracting Reports (ISRs)

As a reminder, Other Than Small Businesses (OTSB) {also known as large businesses eSRS Home Page(LB)} are required to submit their Individual Subcontract Reports via the Electronic Subcontract Reporting System (eSRS) by 30 April 2015 (prime contractors and applicable large business first tier subcontractors).  Throughout the course of my blog I have posted several articles on the reporting requirements, you can review the following posts for further guidance:

For addition information you can visit the eSRS site for training guides and sample reports.

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Foreign Affairs Security Training Center Project (FASTC)

Project Updatefireams_150_1

Contractors interested in pursuing the FASTC project, to be constructed at the Virginia National Guard Maneuver Training Center, Fort Pickett, VA, GSA has announced the availability of the Supplemental Draft Environment Impact Statement (EIS).  An electronic version of the statement and other valuable information related to the project can be viewed at: http://www.state.gov/recovery/fastc/

Key project information available so far:

  • Solicitation documents were made available 5 Jan at fbo.gov
  • The SF 1442 posted indicates step 1 Request For Qualifications are due 4 Feb 2015, 12 PM EST. However this conflicts the 5 Feb 2015 date listed in other documents posted at FBO.
  • The Pre-proposal conference is scheduled for 21 January 2015 at 11:00 AM EST at The Strawbridge Building, Philadelphia, PA. Interested parties must email the Contracting Officer by cob 01/19/15 to confirm their attendance. Only prime contractors may attend this conference.
  • The Public Information Meeting regarding the EIS will held Monday, 26 January 2015 from 7-8 PM EST at the Blackstone Conference and Retreat Center, Blackstone, VA. There will be a 45 day review and comment period which runs from 9 Jan – 23 Feb 2015.  All comments are due by 23 Feb 2015.
  • RFIs for step one should be submitted to the Contracting Officer by 30 Jan 2015.  Responses will be posted to FBO via amendment(s).

2014 Year in Review

Tower Crane 2

Thanks to my blog readers during 2014 – your views and comments have helped shaped the content I post.  2014 marked the second full year of my blog and it tallied over 6100 views, almost triple the views registered during 2013.  The “Standard Form (SF) 1413 Statement and Acknowledgement Compliance Tips” post continues to be the most highly read of all time.

Throughout the year I posted a blend of original content, several blog articles from 2013, and reblogs from other sources such as Harvard Business Review.

Below is a consolidated list of articles from 2014:

Top Five Most Popular Blogs of 2014:

I look forward to continuing in 2015 with a continued focus on federal contracting and partnering.  In particular I will take a closer look at small business contracting issues and initiatives, Small Business Liaison Officer training, project team communication, partnering setting goals and achieving them, and project team communication and collaboration.

Happy New Year!

Small Business Program Policies and Procedures Manual

Policy ManualIf your firm is a large business federal contractor does it have a small business program policy and procedures manual and an assigned small business liaison officer (SBLO)?

Two of my earlier posts dealt directly with the Establishment a Small Business Program and Small Business Utilization Surveillance and Reporting.  To continue the theme, this post deals directly with the content and benefits of a policy and procedures manual for a federal contractor’s small business program.  One of the central reasons for implementing a policy and procedures manual is to provide your federal contracting team with the guidance, knowledge and resources to lead and manage a successful program.  In addition, it can elevate your firm’s small business program from maintaining baseline compliance to a comprehensive small business program that establishes key performance indicators for those leading and working with your federal contracting team.  This is the first step in pursuit of being awarded the Dwight D. Eisenhower Award For Excellence – the SBA’s award for large prime contractors that have excelled in their utilization of small businesses as suppliers and subcontractors.

The main purpose of this post is to provide a few examples of the content that should be included in your firm’s manual and generate a few thoughts of what you think are relevant.  That said, this post is not a manual on the theory, structure, and format of drafting a policy and procedures manual.  (There are a number of great resources available to address those concerns.)  While many business share similar characteristics, such as business type, location, or market each firm is unique and must tailor the manual to fit its needs.

What should a policy and procedures manual for a small business program office contain?

  1. The CEO’s vision, intent, and policy letter articulating his or her intent. This will allow the team to operate effectively and efficiently with minimal supervision.
  2. The mission statement for the small business program.
  3. An organizational matrix and narrative outlining the small business team and its relationship to the company’s leadership and other departments. This is helpful because you may be asked to provide this during an audit.
  4. Federal subcontracting guidelines and definitions.
  5. A library of references, templates, and tools:
    1. Subcontracting plan templates for the various agencies
    2. Small business Self-certification forms
    3. Small business utilization tracking templates
    4. First tier large business subcontractor guidelines and notification letters
    5. Subcontracting plan review guidelines (to assist with the review of your first tier large business subcontractor subcontracting plans)
  6. A description of your firm’s ongoing small business outreach efforts. For example, what events, conferences, or functions centered on boosting small businesses does your firm participate in regularly.
  7. Guidelines for your firm’s participation in Mentor-Protégé Programs.
  8. Internal and external training programs on small business.

Benefits:

  1. The small business team will be able to operate more effectively and efficiently.
  2. Compliance efforts will be reduced.
  3. Streamlined integration with other departments.
  4. Potential gains in small business utilization.
  5. Stronger relationships with the small business community and potential long term strategic small business partners.

Resources:

Summary

There are a number of styles and approaches available to help you develop a policies and procedures manual, but the first step along the journey is to identify what is needed.  The manual should be a living document that can mature as your company refines its processes.  In addition, through the process of drafting the manual you will identify and correct processes and procedures that need improvement.  I have drafted compliance guides for clients which turned out be an enlightening experience.  Particularly during the interview process, clients realize there are weaknesses in their program that can have a negative impact on their small business program.  When you are ready, you can tackle the completion of your firm’s federal contracting policies and procedures manual addressing the full spectrum of contracting matters.

Construction Project Team Partnering (Team Facilitation)

IntroductionRowing

For the past 18 months I have been facilitating several project teams on medium and large complex healthcare construction projects in addition to providing other consulting services on projects around the country.  Over the next 12 months I will devote several posts on project team facilitation to share concepts, lessons learned, and resources for partnering.

In addition to writing about facilitation I will continue to post articles on government contracting with a special emphasis on compliance and small business topics.  Over the past year the top three articles are:

  • Standard Form 1413 Statement and Acknowledgement Form
  • Government Agency Small Business Mentor Protégé Programs
  • The Value of developing a FAR Matrix during proposal development

What is Facilitation

In my previous role as a military Inspector General and Joint Operations Planner, and consultant I have found facilitation very effective in helping military units and teams work through problems and increase efficiency, morale, and readiness.  Also, I carry some of my aircrew coordination training from the military in toolkit as a facilitator.  I believe the seven critical components of crew coordination carry over to project team facilitation, but four standout as particularly relevant based on my experience:Thunderbirds

  • Communication
  • Leadership
  • Adaptability/Flexibility
  • Situational Awareness

In general terms project team facilitation can be viewed as the process of an unbiased person helping a group identify, express, and solve problems, make decisions, and improve effectiveness.  Several key components of a group include how a group works together, the structure / composition of the team, and topic or subject the team is working on, i.e. the construction of a headquarters complex for the government client.

There are two, of many, factors that can influence the successful outcome of facilitation I would like mention.  First, it is important to select a facilitator that fits the group and is acceptable to all members of a group or team.  Second, the group members should be open to the concept of facilitation and participate in the sessions.  Without them the facilitation effort to move the team to a fully functioning group could move slower than desired.

Benefits of Facilitation

The benefits of facilitation are numerous and often reflect the effort everyone (to include the facilitator) contributes to a successful outcome.  To claim any wins resulting from the facilitation effort it is necessary to develop reasonable metrics to monitor the team over time, otherwise it will be difficult to measure any progress.  That said, several benefits include:

  • More efficient / effective teams
  • Better communication between owner – contractor
  • Improved problem solving – the entire team owns problems
  • Conflicts are resolved at the lowest possible level and those that can’t be resolved are escalated in accordance with the team’s escalation matrix.

For some, a facilitator is just an added expense to the project, but based on my experience of having benefited from facilitation as a project manager and as facilitator the benefits gained far outweigh the direct cost.  Often schedule gains can be realized, trouble areas can be identified earlier, and costly delays can be mitigated.  These all lead to improved project delivery and can provide for a more enjoyable work environment for the whole team, owner and contractor.

Mid-Year Individual Subcontract Reports

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.

Quick Tips:

  • 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.

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.
  • Mid-year Summary Subcontract Reports are not required any longer for DoD.

 

Federal Contracting Subcontractor Payment & Retainage Considerations

After working with a client recently I thought it appropriate to discuss withholding and AIA_Billingretainage considerations for Federal contractors.  Similar to many other facets of government contracting, it is wise to be fully aware of the Federal Acquisition Regulation clauses in your contract and their impact on your business decisions.  So one tool a contractor has to encourage a particular behavior is to withhold payment from a subcontractor.  However, there are a few rules to live by.

Under the Prompt Payment for Construction Contracts Clause (FAR 52.232-27) payment to subcontractors is required within seven (7) days of receipt of funds paid to the Contractor.  Under this clause “Subcontractor Payment Entitlement” the contractor may not request payment from the Government any amount withheld or retained under this clause.  However, this clause does not limit or restrict the right of a contractor or subcontractor at any tier to retain (without cause) payment for work performed without incurring any obligation to pay late payment interest penalty.  The amount (percentage) to be retained is not stipulated in this clause, it is negotiated in the subcontract.  This allows flexibility based on unique factors of each subcontract.

Should this tool become necessary, the general requirements for retainage & withholding payment include:

  1. Provide notice to the subcontractor specifying:
    1. The amount withheld;
    2. The specific causes for the withholding under the terms of the subcontract; and
    3. The remedial actions to be taken by the subcontractor in order to receive payment of the amounts withheld.
  2. Provide a copy of the subcontractor notification to the Contracting Officer.

Under extenuating circumstances the determination of the need for retainage, or withholding payment from a subcontractor may be discovered after making a request for payment to the Government, but before making payment to the subcontractor.  If it is determined that all or a portion of the payment due to the subcontractor is subject to withholding under these circumstances, the following must be complied with:

  1. Subcontractor Notice – Provide notice as soon as practicable upon ascertaining cause for withholding, but prior to due date for payment to subcontractor {FAR 52.232-27(g)}.
    1. The amount withheld;
    2. The specific causes for the withholding under the terms of the subcontract; and
    3. The remedial actions to be taken by the subcontractor in order to receive payment of the amounts withheld.
  2. Contracting Officer Notice – Provide notice to the Contracting Officer (copy of the subcontractor notification), as soon as practicable {FAR 52.232-27(e)(1)}
  3. Subcontractor Progress Payment Reduction – reduce the subcontractor’s progress payment by an amount not to exceed the amount specified in the notice of withholding furnished to the Contracting Officer and Subcontractor {FAR 52.232-27(e)(1)}.
  4. Subsequent Subcontractor Payment – Pay the subcontractor as soon as practicable after the correction of the identified subcontractor performance deficiency, and;
    1. Make payment within seven (7) days after correction of subcontractor MoneyChangingHands_webperformance deficiency (unless funds must be recovered from the government).
    2. Make payment within seven (7) days after funds are recovered from the government.
    3. Contractor to incur an obligation to pay interest for late payments in accordance with FAR 52.232-27(e)(4)(ii).
  5. Notice to the Contracting Officer, upon:
    1. Reduction of the amount of any subsequent certified application for payment.
    2. Payment to the subcontractor (withheld amounts and corresponding dates of withholding).
  6. Interest to Government – Provide interest payment to the government as stipulated by FAR 52.232-27(e)(6) for late payments.

As with many contractual issues it is always recommended to discuss withholdings and retainage with legal counsel for any questions or concerns.

Government Agency Small Business / Mentor Protégé Programs (MPP)

The first two posts in this three part series discussed small business mentoring and development programs available through private industry and several professional associations in the construction industry.  The focus of this post as the finale is to provide an overview of mentoring programs available through government agencies.  Most government agencies have a Mentor-Protégé program that encourages agreements between large and small business prime contractors and eligible small business protégés.  Mentor-Protégé Programs are designed to motivate and encourage firms to assist small businesses with business development.  Also, many of the agency MPP websites include links to:

  • The necessary documents for applying
  • An overview of the application process
  • Benefits to the mentor and protégé
  • Lists of existing mentors, portages, and/or current program agreements

Please refer to the list at the end of acronyms and terms.

Small Business Administration 8(a) MPP

SBA Image

The 8(a) Business Development (BD) MPP is designed to enable successful firms to provide various forms of business development assistance. The goal of the 8(a) BD Mentor-Protégé Program is to enhance the capability of 8(a) Program Participants to be competitive and achieve entrepreneurial success.

Protégé Requirements

Mentor Qualifications

Must be an 8(a) BD program member and in good standing. Must possess favorable financial health, including profitability for two years.
Must not have received an 8(a) contract previously. Must possess good character.
Must meet certain size restrictions (see the SBA’s website for details). Must not appear on the federal list of debarred or suspended contractors.
Must be able to impart value to the protégé through practical experience gained through the 8(a) program.

See CFR 124.520 “What are the rules governing SBA’s Mentor/Protégé program?” for additional information.

Department of Defense (DOD)

DoD MP Image

The DoD MPP assists small businesses (protégés) to successfully compete for prime contract and subcontract awards by partnering with large companies (mentors) under individual, project-based agreements.  There are two types of agreements under the DoD program: Direct Reimbursement and Credit (refer to the website for additional information.

Protégé Requirements

Mentor Qualifications

A qualifying organization employing the severely disabled. The Mentor firm must be currently performing under at least one active approved subcontracting plan negotiated with DoD or another Federal agency pursuant to FAR 19.702.
WOSB Eligible for the award of Federal contracts.
HUBZone New Mentor Applications must be approved and may be submitted to and approved by the OSBP of the cognizant Military Service or Defense Agency (if concurrently submitting a reimbursable Agreement) or to the DoD OSBP office prior to the submission of an Agreement.
SDB
SDVOSB
A businesses that are owned and controlled by an Indian tribe or a Native Hawaiian organization.

Department of Veterans Affairs (VA)

VA MPP Image

The purpose of the VA MPP is to provide developmental assistance to Service-Disabled Veteran-Owned Small Businesses and Veteran-Owned Small Businesses that will enhance their capabilities to perform as prime contractors and subcontractors on VA procurements.  If you are interested in applying, the VA program only accepts applications during specified open enrollment periods; refer to the website periodically for updates and announcements.

Protégé Requirements

Mentor Qualifications

Limited to protégés that provide goods or services the VA procures. May be small or large business and either a prime or subcontractor.
Protégés must be verified by CVE as a VOSB or SDVOSB and maintain their status. Must be able to provide appropriate developmental assistance.
VOSB or SDVOSB Financial capacity to provide development assistance to the protégé.
Limited to one VA mentor at a time.

 

General Services Administration (GSA)

GSAlogo

GSA’s MPP is designed to encourage and motivate GSA prime contractors to assist small businesses and enhance their capability of performing successfully on GSA contracts and subcontracts. The goal is to increase the overall number of small businesses receiving GSA prime contract and subcontract awards, resulting from mentorship and refined business practices.

Protégé Requirements

Mentor Qualifications

To be eligible for selection as a protégé, your small business can qualify by simply being a small business (SB, SDB, WOSB, HUBZone, VOSB, SDVOSB). Must be a prime contractor on a GSA Schedule or GSA contracting vehicle, such as a BPA, IDIQ, or GWAC.  If your business is large, that vehicle must include an approved subcontracting plan as required by FAR 19.7
Your business must meet the definition of a small business concern outlined at FAR 19.001. Per this regulation, it is the Small Business Administration that establishes small business size standards on an industry-by-industry basis. As a mentor, you must be able to guarantee that you can provide developmental assistance to enhance the capabilities of protégés to perform as

  • Contractors,
  • Subcontractors, and /or
  • Suppliers
A small business prime contractor is NOT required to have an approved subcontracting plan in place to qualify as a mentor.

Department of State

DoS Image

The DoS MPP is designed to motivate and encourage large business prime contractor firms to provide mutually beneficial developmental assistance to SBs, VOSBs, SDVOSBs, HUBZone small businesses, SDBs, and WOSBs.  The program is formulated to foster the establishment of successful long-term business relationships between State Department, large prime contractors and small business subcontractors thereby improving the performance of both.  The program is intended to strengthen subcontracting opportunities and accomplishments at the State Department.

Protégé Requirements

Mentor Qualifications

Small in the NAICS code for the services or supplies to be provided by the protégé to the mentor Capable of providing appropriate developmental assistance to enhance the capabilities of protégés to perform as contractors and/or subcontractors.
An SB, HUBZone, SDB, WOSB, VOSB, or SDVOSB as those terms are defined in FAR 2.101 May be either a large or small business
Protégés may have multiple mentors. Protégés participating in mentor-protégé programs in addition to DoS’s program should maintain a system for preparing separate reports of mentoring activity for each agency’s program. Will be encouraged to enter into arrangements with protégés and firms with whom they have established business relationships
Mentors may have multiple protégés. However, the DoS reserves the right to limit the total number of protégés participating under each mentor firm for the Mentor Protégé Program

Other Agency Programs

Agency

Link

Department of Homeland Security (DHS) http://goo.gl/56E8mK
Department of Energy http://goo.gl/QuPqMX
Environmental Protection Agency (EPA) http://goo.gl/HQBxMf
Department of Treasury http://goo.gl/BvPwl4
Federal Aviation Administration http://goo.gl/mzAChH
NASA http://goo.gl/3Fnncx
USAID http://goo.gl/Tdy6zm

Acronyms and Terms

CVE – Center for Veterans Enterprise

FAR – Federal Acquisition Regulations

HUBZone – HUBZone Small Business

MPP – Mentor-Protégé Program

NAICS – North American Industry Classification System

OSBP – Office of Small Business Programs

PTAC – Procurement Technical Assistance Center

SDB – Small Disadvantaged Business

SDVOSB – Service Disabled Veteran Owned Small Business

VOSB – Veteran Owned Small Business

WOSB – Women Owned Small Business

Construction Professional Association Small Business Programs

In the last post regarding small business resources I discussed programs offered by general contractors designed to boost small business participation and provide developmental assistance in kind.  This post focuses on programs offered through professional associations targeted at small business utilization and development.  In the construction field one of the most well-known advocates of small business is the Society of American Military Engineers, however this post will cover programs offered through associations as well.  As a reminder, this not an endorsement of one program over another, but it is meant to serve as an awareness tool for small business owners so they are better informed of available resources.  The summaries provided are adapted from the respective associations’ websites, contact the associations below if you would like more information.  Information presented is limited to information readily available on the organizations’ websites.

Sheet Metal and Air Conditioning Contractor’s National Association (SMACNA)SMACNA Logo

SMACNA website outlines several multi-day programs that would be beneficial to all businesses, but small or emerging businesses might benefit the most.

  • Succession Planning – This program touches on the key elements of succession planning and transferring ownership to the next generation such as ownership transfer, defining goals and objectives, leadership development, business valuation, and contingency planning.
  • SMACNA Business Management University – The management program is designed specifically for future managers and owners of SMACNA member companies. The program offers opportunities and training on networking, financial management, strategic planning, negotiation, bonding, and leadership.
  • SMACNA Financial Boot Camp – This program develops the skills and ability of individuals without a financial background, not currently working in finance, or new to contracting with a better understanding of a firm’s financial situation to improve decisions making.

American Subcontractor AssociationASA_Logo

The ASA does not list a specific program targeted at small businesses, but there is an upcoming program featured to occur during the next conference in New Orleans given by a family business owner designed to share challenges and strategies to advance family businesses.

Associated Builders & Contractors, IncABC_Logo

ABC doesn’t list a specific small business program, but several features of membership might be beneficial to some small businesses.  Such as the Accredited Quality Contractors program and the Strategic Partnership Program.  As described by ABC the AQC program honors construction firms which have documented their commitment in five key areas of corporate responsibility: quality, safety, training, community relations, and employee benefits.  The SPP offers select companies the unique opportunity to forge special relationships with ABC members.  (Refer to the AQC hyperlink above for more details)

Washington Building Congress

WBC has a designated Small Business Committee with a charter to expand WBC’s visibility and opportunity to small business and make WBC membership and governance more diverse.  The committee also has specific events focused on networking opportunities for small business to meet and interact with other large business members of WBC.  WBC has a strong membership program making the events well attended.  The committee also conducts periodic training sessions for their small business members.

Society of American Military EngineersSAME_Logo

SAME established a Small Business Council with a detailed charter that outlines the mission and execution of the SBC’s role as an advocate for small businesses.  The national committee and the posts SBC carry out a number of activities and events to advance small businesses, but I will outline a couple.  The biggest event of the year is the annual Small Business Conference held in various locations around the country.  The 2014 conference is scheduled for 8-10 December in Kansas City, MO.  Local posts often host small business events designed to offer education and networking opportunities targeted at small businesses.  The local events are great venues for small or emerging firms to connect with large businesses to learn about subcontracting opportunities in their specific region.

2014 NDAA Allows Prime Contractors to Count Lower Tier Small Businesses

For a quick break in the current series, I want to briefly talk about an upcoming change in small business subcontracting resulting from the 2014 National Defense Authorization Act (NDAA).  On 26 December 2013 President Obama signed the NDAA into law.  While there is much discussion on funding levels for the Department of Defense (DoD) and its programs, there are other features of the NDAA of interest to DoD OSBP Image 2federal small business interest groups.  Specifically, prime contractors will be able to count lower tier small business contractors towards the prime contractor’s small business subcontracting goals.  Based on what is known today, it should be noted the new policy allowing primes to count lower tier small business subcontractors won’t eliminate the prime contractor’s responsibility to make a good-faith effort to meet negotiated 1st tier subcontracting requirements.

The objective of this post is to put this concept in front of prime contractors and 1st tier large business subcontractors to use this lead time to prepare for implementation by the Small Business Administration (SBA).  That said, it will be 18-24 months, or longer, before the change is reflected in the acquisition regulations.  In fact, SBA hasn’t issued many final regulations from the Small Business Jobs Act of 2010, despite statutory deadlines set by Congress.  In the meantime large business contractors can take several steps that will prove beneficial regardless of the exact language in the regulations.  In addition to the points raised in my 21 May 2013 post Small Business Utilization Monitoring and Reporting the attributes of a successful small business program are highlighted below:

  1. Ensure the Small Business Liaison Officer post is filled and has a direct report capability to senior leadership in the organization.
  2. Update small business utilization policies and procedures.
  3. Assess the strength and effectiveness of small business outreach program.
  4. Conduct compliance of the prime’s subcontracting program.  The SBA recommends a five year look back.
  5. Conduct initial (as required) and periodic training for employees involved with subcontracting.  The project manager and support staff will require additional assistance to effectively manage the new requirements.
  6. Update small business source lists.
  7. Ensure the proper flowdown of small business subcontracting clauses.
  8. Ensure adequate controls are in place for 1st tier large business subcontracting plan compliance.

Several questions come to mind as we wait for implementation over the next 18-24 months:

  1. Will this impact subcontracting goals for the agencies and primes?
  2. Will the new requirements change the distribution of subcontracting goals within some of the agencies?

In summary, the change probably won’t happen too quickly and there will most likely be more scrutiny placed on prime contractors for enforcement of the requirements at all tiers.  I believe this change will be manageable, but it will be made easier with advance preparation.