Tips on Preparing Subcontracting Plan

Tips on Preparing a Subcontracting Plan
Subcontracting plans are required from “other than small businesses” for acquisitions that meet the threshold established in paragraph (a)(1)(i) of FAR 19.702, Statutory requirements.1
Step 1. Read the key Federal Acquisition Regulation (FAR) clauses for subcontracting to know what is required and the consequences:
a.​ 52.219-8 Utilization of Small Business Concerns. Note in the clause that accepting the contract means you will implement the U.S. policy to maximize opportunities for SBs, SDBs, WOSBs, VOSBs, SDVOSBs and HUBZone SBs2 to the “fullest extent.”
b.​ FAR 52.219-9, Small Business Subcontracting Plan. Identifies the required elements for a small business subcontracting plan submitted before award and addresses mandatory requirements contractors must follow after award, such as “reports.”
i.​ Subcontracting plans are more than just goals and dollars. It tells the story on how you will ensure SBs, SDBs, WOSBs, VOSBs, SDVOSBs and HUBZone SBs will participate.
ii.​ Understand what is a “good faith effort.” “Good faith effort” is defined in paragraph (d)(3) of the Small Business Regulations 13 CFR 125.3. See the Attachment below for the “good faith effort” list.
c.​ 52.219-16 Liquidated Damages-Subcontracting Plan. Consequences of failing to make a “good faith effort” as required by statute. See the Attachment for the definition of “good faith effort” and “failure to make a good faith effort” as defined in the Small Business Administration regulations.
Step 2. Determine what goods and services will be provided in-house and what will be purchased (subcontracted) from other sources.
Step 3. Seek socio-economic small businesses first (i.e., SDBs, WOSBs, VOSBs, SDVOSBs and HUBZone SBs) before small businesses in order to maximize small business subcontracting credit.
a.​ Look for subcontractors that can meet more than one small business definition. Ensure those dollars are credited against all applicable

The only entities not required to submit subcontracting plans are listed in the Federal Acquisition Regulation section 19.702(b).

categories. For example, a $10,000 subcontract to a WOSB who is also SDVOSB is counted for in this way:
$10,000 for WOSB
$10,000 for SDVOSB
$10,000 for VOSB, since by definition a SDVOSB is also a VOSB $10,000 to SB since by definition this company is a SB, too! b.​ Find potential small businesses:
i.​ GSAM 519.705-4(g)
https://www.acquisition.gov/content/part-519-small-business-progra