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  • Question

    Can a large prime contractor simply add in all lower tier small and small diverse usage to their own subcontracting plan? Example: Prime SB Awards $500,000 1st Tier SB Awards $200,000 2nd Tier SB Awards $50,000 Total proposed small business utilization for the prime contractor would be $750,000? Is the Prime only providing one subcontracting plan or would they need to write a normal plan which includes their first tier subs only and then provide a second plan that includes all tiers? Are their disadvantages to including all tiers (other than the possibility of sabotage by competitors)?


    Answer

    The SBA final rule has not yet been implemented into the FAR.  Once the FAR implements the SBA final rule, then you will be able to get credit for lower tier small business subcontractors.  There is only one subcontracting plan per government prime contract.  You would not have different subcontracting plans under your government prime contract for different tiers of subcontracting. 

    As the prime, you may have a subcontracting plan with your subcontracts and it is required for certain subcontracts as per FAR 52.219(d)(9).  However see DFARS deviation (2016-O0009) for DoD Contracts requiring a subcontracting plan. 


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