What Is a Comprehensive Subcontracting Plan

By J.D. Harrison Sept. 29 (Washingtonpost.com) When it approved the defense budget in 1989, Congress added a new testing program designed to simplify the outsourcing process for large defense contractors. Theoretically, the developers say, optimization would result in large prime contractors passing on more work to small businesses. `2. A contractor`s comprehensive subcontracting plan – `failure to seek in good faith to comply with a comprehensive subcontracting plan` means intentional or intentional non-performance in accordance with the requirements of the comprehensive subcontracting plan approved by the contractor or an intentional or intentional act to thwart the plan.“; (1) The Contractor has negotiated a comprehensive subcontracting plan as part of the trial program, which incorporates the provisions of section 8(d)(6) of the Small Business Act (15 U.S.C. the issues mentioned. 637(d)(6)); „(c) Waiver of Certain Small Business Act Subcontracting Plan Requirements.“ – A Department of Defense Contractor is not required to negotiate or submit a Subcontracting Plan under Section 8(d)(4) or (5) of the Small Business Act (15 U.S.C. 637(d)) with respect to a Department of Defense Contract if- „(3) Any Complete Subcontracting Plan of a Contractor requires the Contractor to be with the Secretary At Defence Semi-annually, the following information: The initiative, known as the Comprehensive Subcontracting Plan Test Program, allows large defence contractors to create company- or department-wide subcontracting plans that describe how the company or each of its entities generally intends to collaborate on any work assigned by the federal government.

Whenever one of the participating companies is competing for work, it can present the general strategy of the subcontractor. (ii) This report covers all subcontracts under the main contracts and subcontracts with the Ministry of Defence, regardless of the dollar value of the subcontracts, and is based on the overall subcontracting plan negotiated. `(A) apply to the contractor`s entire business organisation or to one or more of the contractor`s business sectors or operational elements as defined in the subcontracting plan; and „B) The total number of subcontracts that were active under the trial program during the six-month period covered by the report and that would otherwise have required a subcontracting plan under Section 8(d)(4) or (5) of the Small Business Act (15 U.S.C. 637(d)). Reviews commissioned by the Department of Defense (DOD) concluded that the test program for negotiating comprehensive small business outsourcing plans (trial program) avoided millions of dollars in administrative costs for program participants and the DOD. According to the 2013 review, the 12 companies participating in the program at the time avoided costs of approximately $18.5 million by using individual comprehensive outsourcing plans instead of several individual outsourcing plans. A 2007 review also estimated that the Department of Defence avoided administrative costs of at least $45 million in FY2005. The GAO reviewed the methods used for these reviews and took further steps to validate their findings. According to DOD officials, participants could incur significant one-time administrative costs of about $22 million if the testing program is completed or allowed to expire.

The GAO analysis confirms this conclusion. Test program participants and DOD officials interviewed by the GAO said the program has also resulted in non-financial benefits, including greater company-wide awareness of outsourcing opportunities for small businesses. Participants interviewed by gao said that without the program, their businesses may be less inclined to outsource to small businesses. However, they pointed out that the program`s continuous testing state creates uncertainty and prevents further expansion. The 2007 review recommended that the DOD work with Congress to make the testing program permanent; However, the DOD did not respond to this recommendation. This could help eliminate program uncertainty. Today, 25 years after its inception, the Department of Defense website still calls the program a „test,“ explaining that its goal is to „determine whether comprehensive outsourcing plans lead to more opportunities to outsource to small businesses while reducing the administrative burden on contractors.“ „Electronic Subcontracting Reporting System (eSRS)“ means the government-wide electronic, electronic and web-based system for reporting on subcontracting programs for small businesses. The eSRS is located in www.esrs.gov.

(i) This report may be filed on an enterprise, enterprise or subdivision basis (para. B example, a facility or department operating as a separate profit center) as negotiated in the full subcontracting plan with the Defense Contract Management Agency. The idea is that by reducing some of the effort to partner with small businesses and allowing these subcontractors to perhaps be part of a large company`s overall and commonly used network of subcontractors (rather than competing for one-off projects), more work – and more contract funds – would leak to small businesses. « 4. A Ministry of Defence contractor referred to in paragraph 1 is, in respect of a comprehensive subcontracting plan negotiated in a financial year, an undertaking which provides or provides services (including professional services, research and development services and works services) to the Ministry of Defence in the following financial year, in accordance with at least three A`s provided Ministry of Defence contracts with a total value of at least $100,000,000. Since 1990, the DOD has conducted a Congress-led testing program on how contractors report their subcontractor activities. The aim of the programme is to test whether the use of comprehensive subcontracting plans covering multiple contracts between factories, departments or entire companies can lead to administrative cost savings and improve outsourcing opportunities for small businesses. Despite the program`s 25th anniversary, little is known about its effectiveness. `(C) the costs incurred in negotiating, complying with and reporting on full subcontracting plans. (b) Testing programme.

The Contractor`s Comprehensive Small Business Procurement Plan and its successors, approved and approved by the 15 U.S.C. 637 Note Test Program, as amended, will be incorporated into and incorporated into this Agreement. In the event of exclusion from the trial program or expiration of the trial program, the Contractor will negotiate an individual subcontracting plan for all future contracts that meet the requirements of U.S. § 15.C. 637(d). (i) Ensure that subcontractors with subcontracting schedules agree to submit an Individual Subcontracting Report (ISR) and/or a Subcontracting Summary Report (SSR) using the Electronic Subcontracting Reporting System (eSRS). `(D) cost reduction through the adoption of a comprehensive subcontracting plan.` (2) With effect for fiscal year 2016 and each additional fiscal year in which the test program is in effect, the Secretary of Defense shall report to Congress on any negotiated comprehensive subcontracting plan that, in the opinion of the Secretary, has not met the subcontracting objectives negotiated in the plan for the preceding fiscal year. A: Contractors eligible to participate in the test are „large“ companies that (a) operated under at least three doD main contracts in the previous fiscal year, (b) provided supplies or services (including professional services) to the DoD, (c) received $5 million or more for such contracting activities, and (d) received a participation rate of 5% or more to subcontractors in the previous fiscal year (Disadvantaged Small Businesses, SDB).

A „large“ company whose participation rate in SDS subcontracting was less than 5% in the previous fiscal year may be allowed to participate in the test if it presents an acceptable and detailed plan with milestones leading to a participation rate of at least 5% among SDS subcontractors. The National Defence Authorization Act for fiscal year 2015 included a provision allowing the GAO to report on program results. This report examines the extent to which the program (1) reduces administrative costs and (2) improves subcontracting opportunities for small businesses. .

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