Attachment 3: APU No. 26-01 Mandatory Staffing Plan for all SB Preference Program Awards and Solicitations

DEPARTMENT OF THE TREASURY

WASHINGTON, D.C.

Acquisition Procedures Update No. 26-01
November 7, 2025

MEMORANDUM FOR BUREAU CHIEF PROCUREMENT OFFICERS

Alan J.
Monico Jr.

Digitally signed by Alan
J. Monico Jr.
Date: 2025.11.07
19:06:18 -05'00'

FROM:

Alan J. Monico Jr.
Acting Senior Procurement Executive

SUBJECT:

Acquisition Procedures Update (APU) No. 26-01, Mandatory Staffing Plan and Monthly Contractor Workforce reporting deliverables for all solicitations and awards set aside under any small business socioeconomic program authorized by the Federal Acquisition Regulation (FAR) Part 19.

1. Purpose: This APU establishes Department-wide policy requiring contracting officers to include two contractor workforce transparency deliverables— (1) an initial staffing plan and (2) a post‑award monthly workforce report—in every solicitation, contract and ordering vehicle for services acquired through a set-aside program. 2. Effective Date: This policy is effective immediately upon issuance. 3. Expiration Date: Until otherwise canceled, superseded, or included within a future edition of the DTAP.
4. Applicability: This policy applies to all Treasury bureaus and offices and governs all small business set-aside acquisitions for services. It applies to all solicitations, contracts, task and delivery orders, and calls/orders set aside under any small business socioeconomic program authorized by the Federal Acquisition Regulation (FAR) Part 19. 5. Background: The Federal Acquisition Regulation (FAR) emphasizes strategic planning and effective management of service acquisitions to ensure performance, accountability, and prudent use of taxpayer resources. Enhanced visibility into contractor staffing supports performance management, strengthens quality assurance surveillance, and informs strategic sourcing and category management across Treasury.
This policy reinforces compliance with FAR 52.219-14, Limitations on Subcontracting, which mandates that small business preference program prime contractors (8(a), WOSB, HUBZone, and SDVOSB firms) perform a prescribed percentage of work with their own personnel. Specifically, under FAR 52.219-14(e), a small business prime may not pay more than 50 percent of the amount paid by the government to subcontractors that are not similarly situated, depending on contract type. For service contracts, this ensures that the small business prime contractor retains meaningful control and participation in contract performance, preserving the integrity and intent of the small business programs.