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  • Question

    Based on the scenario above, how is it possible to negotiate any type of subcontracting plan percentages with large prime contractors at the base level when everything is unknown at the base level. Based on FAR 19.705-1(b)(2), KOs are allowed to negotiate goals at the TO level (when requirements are known); however, does eSRS currently have the capability to allow for one approved subcontracting plan at the base level with separate/individual goals for each awarded TO? For individual TOs, how can separate goals/achievements be monitored? Do you have an example or good practice for subcontracting plan approval and monitoring in situations like these?


    Answer

    Yes, eSRS does have the capability to allow for subcontracting at both the IDIQ and Task Order level.  Per the eSRS website, " Order Level Reporting Requirement - FAR Case 2014-003 Final Rule will go into effect for the FY18 reporting period of October 1 2017 - March 31 2018. The rule requires contractors who are awarded indefinite delivery, indefinite quantity contracts that can be used by more than one agency to submit order level subcontracting data for each task and delivery order awarded. Only contractors who have an Individual Subcontracting Plan are affected by this rule. eSRS will be enhanced to allow for order level reporting through the Batch Upload function." 
     
    Outside the guidance in FAR 19.705-2(e), the FAR doesn't provide many specifics on subcontracting plan goals within an IDIQ arrangement.  But goals are typically listed for the master contract as well as all orders generated under the contract.  The IDIQ goals can be based on estimated quantities, number of orders to be awarded, or the sample task order(s)/seed projects.  In your scenario with a lot of "unknowns", goals may need to be based on the initial seed projects or historical data with SBA input.  Subcontracting Plan monitoring varies by the type of subcontracting plan and by local policy.  So, it would be wise to consult with your Small Business Specialist.


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