A subcontracting plan is a plan the university develops and adopts for subcontracting parts of its contract work to further the government’s program to assist small businesses under the Small Business Act and to comply with North Carolina State Purchasing Policy.
Many federal agencies require probable successful offerors for agreements of $700,000 and greater to provide formal subcontracting plans. Subpart 19 of the Federal Acquisition Regulation requires that subcontracting provide:
- Percentage goals for using small business (SB), small disadvantaged business (SDB), and women-owned (WOSB) concerns;
- The name of the individual who will administer the subcontracting program;
- A description of the efforts the university will make to ensure that small business has an equitable opportunity to compete for subcontracts;
- Assurances that the university will include the requirement for a subcontracting plan in each of its subcontracts of $700,000 and greater that is not awarded to one of the categories of small business cited above;
- Assurances that the offeror will cooperate in studies or surveys and submit periodic reports;
- For Department of Defense contracts, efforts to seek participation by Historically Black Colleges and Universities (HBCUs); and
- A recitation of the records the university will maintain to demonstrate compliance.
Federal Acquisition Regulations state that contractors and subcontractors failing to comply in good faith with the requirements of a subcontracting plan are in material breach of contract. This can result in termination for default — which would have a seriously adverse universitywide impact.
- Receives the request for the plan from the sponsor or faculty member and prepares the outline of the plan, which includes a narrative description of the effort being made to subcontract with a small business (SB), small disadvantaged business (SDB), and/or women-owned small business (WOSB) and the generic format for the information to be provided by the proposal writer(s).
- Contacts the college, school, or unit office and/or the principal investigator (PI) for a list of the equipment, material and/or services to be purchased.
- Compiles a list of equipment/materials/services to be purchased.
- Provides information on how the source was selected (i.e., working with University Purchasing). This includes written quotes and a justification for all sole source buys.
- Compiles a list of subcontract(s) contemplated, including those to other universities, with proposal(s) from the prospective subcontractor(s) that has information on funding and the period of performance.
- Provides information on an attempt to utilize a Historically Black College or University (HBCU) in the research. If an HBCU is not included as a collaborator in this research effort, provides a statement that one could not be found with the requisite capabilities (DoD agencies only).
- Compiles the Small Business Plan and its appropriate attachments, working with the sponsor.
- Obtains university approval and signature(s).
- Makes the submission to the sponsor and appropriate distribution.