REG 10.10.05 – Procedures for Creating and Managing Small Business Subcontracting Plan
Authority: Vice Chancellor for Research and Innovation
History: First Issued: April 16, 1993. Last Revised: October 9, 1995.
Additional References:
Public Law 95-507, Subpart 19 of the Federal Acquisition Regulation
Contact Info: Vice Chancellor for Research and Innovation (919-515-2117)
1. Vision
The vision of this initiative is to contribute to promoting most favorable relationship possible between the federal agency sponsors of research and North Carolina State University by the timely development and submission of Small Business Subcontracting Plans
2. Objectives
2.1. To blend existing processes with whatever new methods are necessary to create the symbiotic relationship between all the University activities involved to make the vision a reality. At a minimum, the University must:
2.1.1. set reasonable goals acceptable to the Federal Government;
2.1.2. develop ways of attempting to achieve the goals beginning at the proposal writing stage; and
2.1.3. track performance
2.2. To foster an information flow between the various activities at the University that have a part in the required planning, formulating, negotiating and reporting on subcontracting with Small Business (SB), Small Disadvantaged Business (SDB), and Women Owned Small Business (WOSB).
3. Goals
3.1. Evidenced by the growing number of Small Business Subcontracting Plans that have been successfully executed to date, we can put them in place when required. However, these early accomplishments have made it very clear, as the numbers of these plans increase, that much in the present process inhibits acceptability, timeliness and cost/time affectivity. Accordingly, in an effort to improve the University response to this federal requirement better connectivity between the activities involved and some changes in the sequence events in the process must be brought about.
3.1.1. Goal 1: To Assure Understanding of the Requirement by Research Faculty
3.1.2. Goal 2: Establish a Process by which Research Faculty Offices can seek Small Business or State Contract source information for their requirements.
4. The Plan
A subcontracting plan is a plan, developed and adopted by the University, for subcontracting parts of its contract work to further the government’s program to assist small businesses under the Small Business Act and to comply with North Carolina State purchasing policy.
Many federal agencies require probable successful offerors for agreements of $500,000 and greater to provide formal subcontracting plans. Subpart 19 of the Federal Acquisition Regulation requires that subcontracting provide:
4.1. Percentage goals for using small business (SB), small disadvantaged business (SDB), and women owned (WOSB) concerns;
4.2. The name of the individual who will administer the subcontracting program;
4.3. A description of the efforts the University will make to endure that small business has an equitable opportunity to compete for subcontracts; and
4.4. Assurances that the University will include the requirement for a subcontracting plan in each of its subcontracts of $500,000 and greater that is not awarded to one of the categories of small business cited above.
4.5. Assurances that the offeror will a. cooperate in studies or surveys, and b. submit periodic reports.
4.6. For DoD contracts, seek participation by Historically Black Colleges and Universities (HBCU’s).
4.7. A recitation of the records the University will maintain to demonstrate compliance.
Federal Acquisition Regulations state that contractors and subcontractors failing to comply in good faith with the requirements of a subcontracting plan are in material breach of contract. This can result in termination for default which would have a seriously adverse university-wide impact.
5. Preparing a Small Business Plan
5.1. Step 1. Sponsored Programs and Regulatory Compliance Services
5.1.1. Receives the request for the plan from the sponsor or faculty member, prepares the outline of the plan which includes a narrative description of the effort being made to subcontract with small business (SB), small disadvantaged business (SDB), and women owned small business (WOSB) and the generic format for the information to be provided by the proposal writer(s),
5.1.2. Contacts College/School/Unit office and/or Principal Investigator for list of equipment/material/services to be purchased.
5.2. Step 2. College/School/Unit office and/or Principal Investigator
5.2.1. Compiles a list of equipment/materials/services to be purchased,
5.2.2. Provides information on how source was selected [working with Pro-Net (http://pro-net.sba.gov) and University Purchasing]. This includes written quotes and a justification for all sole source buys,
5.2.3. Compiles list of subcontract(s) contemplated, including those to other universities, with proposal(s) from the prospective subcontractor(s) with information on funding and period of performance,
5.2.4. Provides information on attempt to utilize a Historically Black College or University (HBCU) in the research. If an HBCU is not included as a collaborator in this research effort, provides a statement that one could not be found with the requisite capabilities (DoD agencies only).
5.3. Step 3. Sponsored Programs and Regulatory Compliance Services
5.3.1. Compiles the Small Business Plan and its appropriate attachments, working with the Sponsor,
5.3.2. Obtains University approval and signature(s),
5.3.3. Makes the submission to the sponsor and appropriate distribution.