Answers to Questions 4

1. Controlling clause and calculation. The updated solicitation lists FAR 52.219-14 (October 2025) by reference. Please identify or provide the exact applicable clause text and any agency deviation. For this services requirement, please confirm the applicable percentage limit and calculation basis for amounts paid to subcontractors that are not similarly situated, including the treatment of materials and any other permitted exclusions.
ANSWER: 52.219-14 Limitations on Subcontracting. As prescribed in 19.104-3(c) Limitations on Subcontracting (OCT 2025) (DEVIATION 26-03). Services (except construction), it will not pay more than 50 percent of the amount paid by the Government for contract performance to subcontractors that are not similarly situated entities. Any work that a similarly situated entity further subcontracts will count towards the prime contractor's 50 percent subcontract amount that cannot be exceeded. When a contract includes both services and supplies, the 50 percent limitation shall apply only to the service portion of the contract;
2. Similarly situated subcontractors. For this total small-business set-aside, may a first-tier subcontractor that is small under the NAICS code assigned to its subcontract qualify as similarly situated? Please confirm how amounts paid to that subcontractor are treated, and how its further subcontracting to entities that are not similarly situated counts toward the limitation. Is there a separate minimum portion that the prime must perform with its own employees, apart from compliance with the applicable limitation and responsibility for performance?
ANSWER: The prime contractor may not pay more than 50 percent of the amount paid by the Government for contract performance to subcontractors that are not similarly situated entities. There is no separate solicitation-specific minimum percentage that the prime contractor must perform with its own employees beyond compliance with FAR 52.219-14 and applicable SBA limitations-on-subcontracting requirements. 3. Compliance period and evidence. Is compliance measured separately for the base period and each option period, by individual order, or on another basis? Must the initial quote include subcontractor identity, size representations, a workshare

calculation or other supporting evidence, or are those records required only upon request or after award? Please identify any required format and submission deadline. Answer: No requirement of o erors to submit subcontractor identities, subcontractor size