1 Mid-Atlantic Regional Council Meeting Subcontracting and eSRS Wendy Despres Assistant Director for...

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Mid-Atlantic Regional Council Meeting

Subcontracting and eSRSWendy DespresAssistant Director

for Subcontracting Policy,DoD Office of Small Business Programs

Office of Small Business Programs

October 29, 2009

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Subcontracting Goals and achievements

Electronic Subcontracting Reporting System (eSRS)

Contractor Performance Assessment Reporting System (CPARS)

American Reinvestment & Recovery Act

Agenda

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SBSB SDBSDB HUBZoneHUBZone WOSBWOSB SDVOSBSDVOSB

FYFY

Total Total Reported Reported

Subcontract Subcontract Dollars Dollars

GoalGoal $$ %% GoalGoal $$ %% GoalGoal $$ %% GoalGoal $$ %% GoalGoal $$ %%

20082008 $160.7$160.7 37.2%37.2% $50.9$50.9 31.7%31.7% 5.0%5.0% $5.9$5.9 3.7%3.7% 3.0%3.0% $3.0$3.0 1.9%1.9% 5.0%5.0% $8.4$8.4 5.3%5.3% 3.0%3.0% $1.6$1.6 1.0%1.0%

20072007 $127.8$127.8 35.0% 35.0% $46.0$46.0 36.0%36.0% 5.0%5.0% $5.5$5.5 4.3%4.3% 3.0%3.0% $2.2$2.2 1.7%1.7% 5.0%5.0% $6.9$6.9 5.4%5.4%

3.0%3.0% $1.1$1.1 .9%.9%

20062006 $106.6$106.6 35.0%35.0% $39.6$39.6 37.2%37.2% 5.0%5.0% $5.1$5.1 4.8%4.8% 3.0%3.0% $1.8$1.8 1.7%1.7% 5.0%5.0% $5.8$5.8 5.5%5.5%3.0%3.0%

$0.7$0.7 0.7%0.7%

20052005 $121.0$121.0 42.0%42.0% $43.7$43.7 36.1%36.1% 5.0%5.0% $5.4$5.4 4.4%4.4% 3.0%3.0% $1.4$1.4 1.2%1.2% 5.0%5.0% $6.0$6.0 4.9%4.9% 3.0%3.0% $0.5$0.5 0.4%0.4%

20042004 $101.8$101.8 42.0%42.0% $35.2$35.2 34.5%34.5% 5.0%5.0% $4.1$4.1 4.1%4.1% 3.0%3.0% $1.1$1.1 1.1%1.1% 5.0%5.0% $5.0$5.0 4.9%4.9% 3.0%3.0% $0.4$0.4 0.4%0.4%

DOD Small Business Subcontracting DOD Small Business Subcontracting History (Dollars in Billions)History (Dollars in Billions)

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Electronic Subcontracting Reporting System (eSRS) is Electronic Subcontracting Reporting System (eSRS) is part of the President’s Management Agenda for Electronic part of the President’s Management Agenda for Electronic Government (E-Gov) Government (E-Gov) eSRS is under the Integrated Acquisition Environment eSRS is under the Integrated Acquisition Environment (IAE) at General Services Administration (GSA)(IAE) at General Services Administration (GSA)

SBA is the program managerSBA is the program managereSRS eliminates the need for paper submissions and eSRS eliminates the need for paper submissions and processing of Standard Form (SF) 294 and 295s processing of Standard Form (SF) 294 and 295s

Individual Subcontracting Report (ISR) replaces SF 294Individual Subcontracting Report (ISR) replaces SF 294Summary Subcontracting Report (SSR) replaces SF 295Summary Subcontracting Report (SSR) replaces SF 295

eSRS eliminates the need for paper submissions of Year-eSRS eliminates the need for paper submissions of Year-End Report and Small Disadvantaged Business End Report and Small Disadvantaged Business Participation Report (SDB)Participation Report (SDB)

eSRS

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BenefitsBenefitsAllows electronic submission, acceptance, rejection, reporting Allows electronic submission, acceptance, rejection, reporting and analysis of subcontracting data in a real-time paperless and analysis of subcontracting data in a real-time paperless environmentenvironment

Easily accessibly Web-based system Easily accessibly Web-based system

Improves accuracy, timeliness and integrity of data exchangedImproves accuracy, timeliness and integrity of data exchanged

Provides a live interface with Central Contractor Registration Provides a live interface with Central Contractor Registration (CCR) that automatically populates basic vendor information (CCR) that automatically populates basic vendor information based on the DUNSbased on the DUNS

Provides a live interface with Federal Procurement Data System Provides a live interface with Federal Procurement Data System (FPDS) that automatically populates contract data(FPDS) that automatically populates contract data

eSRS

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April 2008 DoD began using system with phased April 2008 DoD began using system with phased approach to deployment that included Army, approach to deployment that included Army, DSCA, DISA and DCMADSCA, DISA and DCMA

FAR eSRS Interim Rule published April 2008 -- FAR eSRS Interim Rule published April 2008 -- updated FAR to require eSRS reporting updated FAR to require eSRS reporting

October 2008 all DoD Services/Agencies using October 2008 all DoD Services/Agencies using FPDS for their contracting data began using eSRS FPDS for their contracting data began using eSRS for their subcontracting reportingfor their subcontracting reporting

Training for DoD users is not supported by SBA Training for DoD users is not supported by SBA and largely performed by BTA and DoD and largely performed by BTA and DoD Components with support from OSBP and DPAPComponents with support from OSBP and DPAP

eSRS

77


DUSD (A&T) Memo dated July 19, 2008:DUSD (A&T) Memo dated July 19, 2008:Required full implementation of eSRS in Oct 2008Required full implementation of eSRS in Oct 2008

Delegated the acknowledge receipt / reject Delegated the acknowledge receipt / reject functions for functions for ISR and SSRISR and SSR

DoD components acknowledge receipt for ISRs for DoD components acknowledge receipt for ISRs for contracts they administer and for contracts on which they contracts they administer and for contracts on which they were the procuring office, but DCMA administerswere the procuring office, but DCMA administers

DoD components acknowledge receipt for SSRs for DoD components acknowledge receipt for SSRs for vendors for which they administer the majority of vendors for which they administer the majority of subcontracting planssubcontracting plans

DCMA approves SSRs for vendors under the DoD DCMA approves SSRs for vendors under the DoD Comprehensive Subcontracting Plan Test ProgramComprehensive Subcontracting Plan Test Program

eSRS

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Deviation to FAR/DFARS issued February 12, 2009 for Deviation to FAR/DFARS issued February 12, 2009 for certain eSRS reporting requirements:certain eSRS reporting requirements:

eSRS does not support submitting ISR for contracts that through eSRS does not support submitting ISR for contracts that through other authority are not required to be reported to FPDS other authority are not required to be reported to FPDS eSRS does not support submitting ISR for orders against Basic eSRS does not support submitting ISR for orders against Basic Ordering Agreements (BOA) and Blanket Purchase Agreements (BPA) Ordering Agreements (BOA) and Blanket Purchase Agreements (BPA)

DoD entities deviate from FAR by using FAR 52.219-9, DoD entities deviate from FAR by using FAR 52.219-9, Small Business Subcontracting Plan (DEVIATION) to Small Business Subcontracting Plan (DEVIATION) to allow for SF 294s for such contractsallow for SF 294s for such contractsDoD entities deviate from the DFARS by using:DoD entities deviate from the DFARS by using:

252.219-7003, Small Business Subcontracting Plan (DoD Contracts) 252.219-7003, Small Business Subcontracting Plan (DoD Contracts) (DEVIATION) (DEVIATION)

252.219-7004, Small Business Subcontracting Plan (Test Program) 252.219-7004, Small Business Subcontracting Plan (Test Program) (DoD Contracts) (DEVIATION) (DoD Contracts) (DEVIATION)

eSRS

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FAR 52.219, Small Business Subcontracting Plan (April 2008)FAR 52.219, Small Business Subcontracting Plan (April 2008)Include in all contracts requiring eSRS reporting (e.g. FAR class deviation Include in all contracts requiring eSRS reporting (e.g. FAR class deviation does not apply) does not apply)

FAR 52.219-9 Small Business Subcontracting Plan (DEVIATION)FAR 52.219-9 Small Business Subcontracting Plan (DEVIATION)Use in contracts when FAR class deviation does apply due to contracts not Use in contracts when FAR class deviation does apply due to contracts not reportable in eSRS and submission of SF 294 is requiredreportable in eSRS and submission of SF 294 is required

DFARS 252.219-7003, Small Business Subcontracting Plan (DoD DFARS 252.219-7003, Small Business Subcontracting Plan (DoD Contracts) (DEVIATION)Contracts) (DEVIATION)

Use in all contracts requiring eSRS reporting that include FAR 52.219-9 Use in all contracts requiring eSRS reporting that include FAR 52.219-9 (April 2008)(April 2008)

DFARS 252.219-7003, Small Business Subcontracting Plan (DoD DFARS 252.219-7003, Small Business Subcontracting Plan (DoD Contracts) (DEVIATION) with Alternate I when FAR 52.219-9 Contracts) (DEVIATION) with Alternate I when FAR 52.219-9 (DEVIATION) is used(DEVIATION) is usedDFARS 252.219-7004, Small Business Subcontracting Plan (Test DFARS 252.219-7004, Small Business Subcontracting Plan (Test Program) (DEVIATION) in all contracts that incorporate a Program) (DEVIATION) in all contracts that incorporate a Comprehensive Subcontracting PlanComprehensive Subcontracting Plan

Which clauses do I use for eSRS?

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Which clauses do I use for eSRS?

**FAR/DFARS clauses for FAR/DFARS clauses for eSRS ReportingeSRS Reporting

eSRS eSRS Reporting Reporting requiredrequired

DoD Class Dev. DoD Class Dev. Feb 12, 2009 Feb 12, 2009 AppliesApplies

****DoD DoD Comprehensive Comprehensive Subcontr. Plan usedSubcontr. Plan used

FAR 52.219-9 (April 2008)FAR 52.219-9 (April 2008) X X

FAR 52.219-9 (DEVIATION)FAR 52.219-9 (DEVIATION) X X

DFARS 252.219-7003 DFARS 252.219-7003 (DEVIATION)(DEVIATION)

X X

DFARS 252.219-7003 DFARS 252.219-7003 (DEVIATION) –Alternate I(DEVIATION) –Alternate I

X X

DFARS 252.219-7004DFARS 252.219-7004(DEVIATION)(DEVIATION)

X X

FAR 52.219-25 (APRIL 2008)FAR 52.219-25 (APRIL 2008)Allows for SDB report in Allows for SDB report in eSRS and may apply to eSRS and may apply to contract IAW FAR 19.12contract IAW FAR 19.12

XX XX XX

*For commercial items use FAR 52.212-5 (Apr 2008) and check these clauses **CSP Participants began using eSRS in Apr 2008

1111


Data used by SBA to report achievements to CongressData used by SBA to report achievements to Congress

OSBP monitors goal achievement, reports to DoD HQ OSBP monitors goal achievement, reports to DoD HQ management, and provides input for the SBA Scorecardmanagement, and provides input for the SBA Scorecard

Goals and achievements for individual DoD components Goals and achievements for individual DoD components cannot be established until 2 complete Fiscal Years of cannot be established until 2 complete Fiscal Years of data are collected in eSRSdata are collected in eSRS

USD (AT&L) memo dated April 16, 2009 establishes USD (AT&L) memo dated April 16, 2009 establishes timelines for acknowledging all eSRS reports and requires timelines for acknowledging all eSRS reports and requires each DoD component to submit an eSRS Status Report to each DoD component to submit an eSRS Status Report to DPAP, OSBP and BTA DPAP, OSBP and BTA

Report due Jun 30 and Dec 30 each yearReport due Jun 30 and Dec 30 each year

Includes # outstanding reports, plans to complete them including Includes # outstanding reports, plans to complete them including a timeline, and barriers to completiona timeline, and barriers to completion

eSRS

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DFARS Clause 252.219-7003 (DEVIATION)DFARS Clause 252.219-7003 (DEVIATION)ISRs: ISRs:

Go to ACO unless ACO is DCMAGo to ACO unless ACO is DCMAIf ACO is DCMA, then ISR goes to PCOIf ACO is DCMA, then ISR goes to PCO

SSRs:SSRs:SSRs for commercial plans go to contracting officer that SSRs for commercial plans go to contracting officer that approved the planapproved the planOne SSR goes to each DoD agency for construction and One SSR goes to each DoD agency for construction and related maintenance and repair contractsrelated maintenance and repair contractsAll other SSRs go to the DoD agency administering the All other SSRs go to the DoD agency administering the majority of the contractor’s individual subcontracting plansmajority of the contractor’s individual subcontracting plans

Note: SSRs for CSP go to DCMA CSP Division IAW Note: SSRs for CSP go to DCMA CSP Division IAW DFARS 252.219-7004 (DEVIATION)DFARS 252.219-7004 (DEVIATION)

eSRS

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DoD Component contracting activities must:DoD Component contracting activities must:Have modified existing contracts to require eSRS Have modified existing contracts to require eSRS reporting as applicable and incorporate eSRS reporting as applicable and incorporate eSRS requirements into all new contract awardsrequirements into all new contract awardsEnsure that ISRs for contracts administered are filed Ensure that ISRs for contracts administered are filed and acknowledged in eSRSand acknowledged in eSRSEnsure that ISRs are accepted by PCOs in eSRS for all Ensure that ISRs are accepted by PCOs in eSRS for all contracts administered by DCMAcontracts administered by DCMA

If DCMA administers/monitors the subcontracting plans, will If DCMA administers/monitors the subcontracting plans, will need ISRs that are accepted by PCOsneed ISRs that are accepted by PCOs

Ensure that SSRs received are reviewed and Ensure that SSRs received are reviewed and acknowledged in eSRS acknowledged in eSRS Comply with eSRS Status Report requirement Comply with eSRS Status Report requirement established by USD(A&T)established by USD(A&T)

eSRS

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CPARS is the DoD system used to assess CPARS is the DoD system used to assess contractor performance IAW FAR 42.15contractor performance IAW FAR 42.15Air Force (AF) initiated action to develop a Air Force (AF) initiated action to develop a performance evaluation area in CPARS for SB performance evaluation area in CPARS for SB UtilizationUtilizationOSBP supported initiative and assisted in OSBP supported initiative and assisted in development of the evaluation area and rating development of the evaluation area and rating definitions and worked with AF and CPARS definitions and worked with AF and CPARS Operational Requirements Committee (ORC) to Operational Requirements Committee (ORC) to implementimplementSB Utilization added to CPARS Feb 2009SB Utilization added to CPARS Feb 2009

CPARS

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Recommended to CPARS ORC to electronically Recommended to CPARS ORC to electronically link eSRS subcontracting reports to CPARS so link eSRS subcontracting reports to CPARS so that users will be able to view the reports as they that users will be able to view the reports as they complete performance assessments (proposed)complete performance assessments (proposed)

Past Performance Information Retrieval System Past Performance Information Retrieval System (PPIRS) ORC will vote on adding the same SB (PPIRS) ORC will vote on adding the same SB Utilization evaluation area so that CPARS SB Utilization evaluation area so that CPARS SB Utilization assessment data will feed into PPIRS Utilization assessment data will feed into PPIRS

Previously, CPARS coverage included small Previously, CPARS coverage included small business subcontracting plan as part of overall business subcontracting plan as part of overall subcontract management and only covered goal subcontract management and only covered goal achievementachievement

CPARS

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New evaluation area more comprehensive New evaluation area more comprehensive assessment of contractor’s utilization of SB – rather assessment of contractor’s utilization of SB – rather than just the achievement of goalsthan just the achievement of goals

Meets the past performance evaluation requirements Meets the past performance evaluation requirements included in FAR 42.15 and 19.7 and DFARS 215.305included in FAR 42.15 and 19.7 and DFARS 215.305

Assesses compliance with terms and conditions of Assesses compliance with terms and conditions of the contract for Small Business participationthe contract for Small Business participation

Assesses compliance with FAR 52.219-8 & 52.219-9 Assesses compliance with FAR 52.219-8 & 52.219-9 including eSRS reportingincluding eSRS reporting

Assesses compliance w/individual subcontracting Assesses compliance w/individual subcontracting planplan

CPARS – SB Utilization

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Compliance with comprehensive plan including Compliance with comprehensive plan including submission of any required program specific datasubmission of any required program specific dataMay require DCMA/ACO/PCO input depending on May require DCMA/ACO/PCO input depending on who is administering the contract or Small who is administering the contract or Small Business Specialist can assistBusiness Specialist can assist

Commercial plan assessment:Commercial plan assessment:Individual contract performance is unknown because Individual contract performance is unknown because plan and reporting is based on commercial items sold by plan and reporting is based on commercial items sold by the entire company, division, plant or product line and the entire company, division, plant or product line and may be approved by another PCOmay be approved by another PCORate contractor satisfactory as long as an approved Rate contractor satisfactory as long as an approved plan is in place and no liquidated damages have been plan is in place and no liquidated damages have been assessedassessed


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Ratings are same as other areas assessed but Ratings are same as other areas assessed but definitions of ratings differdefinitions of ratings differ

Dark Blue/ExceptionalDark Blue/ExceptionalPurple/Very GoodPurple/Very GoodGreen/SatisfactoryGreen/SatisfactoryYellow/MarginalYellow/MarginalRed/UnsatisfactoryRed/Unsatisfactory

SB Utilization also added to ACASS and CCASSSB Utilization also added to ACASS and CCASSFor CPARS guide and other information go to: For CPARS guide and other information go to: http://www.cpars.csd.disa.mil/cparsmain.htmhttp://www.cpars.csd.disa.mil/cparsmain.htm


1919


DoD prime contractors must flow-down to DoD prime contractors must flow-down to subcontractors that are not small subcontractors that are not small businesses applicable FAR and DFARS businesses applicable FAR and DFARS subcontracting clauses, including 52.219-8 subcontracting clauses, including 52.219-8 Utilization of Small Business ConcernsUtilization of Small Business Concerns

DoD prime contractors are responsible forDoD prime contractors are responsible for

Reviewing and approving their subcontractors’ Reviewing and approving their subcontractors’ small business subcontracting plansmall business subcontracting plan

Monitoring compliance of their subcontractors with Monitoring compliance of their subcontractors with their subcontracting planstheir subcontracting plans

FLOW-DOWN REQUIREMENTS

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Degree of monitoring varies depending on Degree of monitoring varies depending on circumstances as they relate to:circumstances as they relate to:

Access to subcontractor recordsAccess to subcontractor recordsSubcontracting dollar amountSubcontracting dollar amountThe subcontractor’s past performance in meeting The subcontractor’s past performance in meeting goalsgoalsOther relevant factorsOther relevant factors

Office of Federal Procurement Policy Office of Federal Procurement Policy guidance, OFPP Policy Letter 80-2, guidance, OFPP Policy Letter 80-2, Supplement 1Supplement 1OSBP working on joint memo with SBA to OSBP working on joint memo with SBA to clarify flow-down requirementsclarify flow-down requirements

FLOW-DOWN REQUIREMENTS

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FLOW-DOWN REQUIREMENTSMonitoring of subcontracting plan compliance Monitoring of subcontracting plan compliance by the subcontractor and subcontractors at by the subcontractor and subcontractors at lower-tiers must include at a minimum:lower-tiers must include at a minimum:

Ensuring that ISRs are submitted by subcontractors Ensuring that ISRs are submitted by subcontractors when requiredwhen requiredAcknowledging receipt of their subcontractor’ ISRs in Acknowledging receipt of their subcontractor’ ISRs in eSRSeSRSComparing performance of their subcontractors to Comparing performance of their subcontractors to subcontracting plan goalssubcontracting plan goalsDiscussing performance with subcontractors when Discussing performance with subcontractors when necessary to ensure their subcontractors make a good necessary to ensure their subcontractors make a good faith effort to comply with their subcontracting plans and faith effort to comply with their subcontracting plans and implement a corrective action plan as neededimplement a corrective action plan as needed

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Status of Subcontracting Reports Status of Subcontracting Reports FY 2008 (Oct – Sept)FY 2008 (Oct – Sept)

As of As of April 21, 2023April 21, 2023

FYFY ReportsReports AcceptedAccepted Pending / RevisedPending / Revised

TotalTotal PrimePrime SubSub TotalTotal PrimePrime SubSub

20082008 Total ISRsTotal ISRs 3,3703,370 3,0303,030 340340 1,2711,271 505505 766766

20082008 Total SSRsTotal SSRs 1,5391,539 -- -- 2424 -- --

20082008 Total Year-Total Year-EndEnd

263263 -- -- 2626 -- --

20082008 Total SDB Total SDB ParticipationParticipation

7171 -- -- 88 -- --

2323


Status of Subcontracting Reports Status of Subcontracting Reports FY 2009 (Sept – March)FY 2009 (Sept – March)

As of As of April 21, 2023April 21, 2023

FYFY ReportsReports AcceptedAccepted Pending / RevisedPending / Revised

TotalTotal PrimePrime SubSub TotalTotal PrimePrime SubSub

20092009 Total ISRsTotal ISRs 4,3074,307 3,7283,728 579579 3,7693,769 2,0692,069 1,7001,700

20092009 Total SSRsTotal SSRs 1,3711,371 -- -- 299299 -- --

20092009 Total Year-Total Year-EndEnd

600600 -- -- 153153 -- --

20092009 Total SDB Total SDB ParticipationParticipation

283283 -- -- 134134 -- --

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The Recovery Act objectives are:To create and save jobs Jumpstart the economyBuild a foundation for long-term economic growth

DoD intends to execute Recovery Act funds as quickly as possible to fulfill these objectives Maximizing awards to small businesses is strongly encouraged by Recovery Act guidance because they generate most of the new jobs in the U.S.

2525



DoD Recovery Act funds (opportunities):

Military Construction - $2.18BFacilities Sustainment, Restoration & Mod. - $4.26BHomeowners Assistance Fund - $550MNear Term Energy-efficient technologies - $300MEnergy Conservation Investment Program - $120M

TOTAL DoD = $7.4B

2626


Reporting Requirements for prime contractors IAW Reporting Requirements for prime contractors IAW (FAR 4.15) include:(FAR 4.15) include:

Dollar amount of invoicesDollar amount of invoicesSupplies or services providedSupplies or services providedCompletion status of the workCompletion status of the workEstimated number of jobs created or retained Estimated number of jobs created or retained Names and total compensation of five most highly Names and total compensation of five most highly compensated officers for the calendar year in which compensated officers for the calendar year in which contract is awardedcontract is awardedSpecific information on first-tier contractorsSpecific information on first-tier contractors


2727


FAR 52.204-11(d)(9) – Each quarter primes FAR 52.204-11(d)(9) – Each quarter primes report aggregate number and total dollar report aggregate number and total dollar amount for subcontractsamount for subcontracts

<$25,000, or<$25,000, orAwarded to an individualAwarded to an individualAwarded to a subcontractor that in the previous Awarded to a subcontractor that in the previous tax year had gross income <$300,000tax year had gross income <$300,000


2828


FAR 52.204-11(d)(10) –First tier subcontracts FAR 52.204-11(d)(10) –First tier subcontracts funded in whole or in part by the Act that are funded in whole or in part by the Act that are >$25,000 and are not reportable under >$25,000 and are not reportable under paragraph (9) must be reported:paragraph (9) must be reported:

Name, Amount, Date, NAICS, Funding Agency, Name, Amount, Date, NAICS, Funding Agency, description of products or services, Subcontract description of products or services, Subcontract NumberNumberSubcontractor must provide to prime the DUNS, Subcontractor must provide to prime the DUNS, physical address, primary place of performance physical address, primary place of performance (including zip and congressional district) and names (including zip and congressional district) and names and compensation of 5 most highly compensated and compensation of 5 most highly compensated officers under certain circumstancesofficers under certain circumstances


2929


Total DoD Awards as of 16 Oct 09Total DoD Awards as of 16 Oct 09Actions 2996Actions 2996Obligations Obligations $2,607,397,511$2,607,397,511

Total DoD Awards to Small Businesses as of 16 Total DoD Awards to Small Businesses as of 16 Oct 09Oct 09

Actions 2272Actions 2272Obligations Obligations $1,529,969,092$1,529,969,092

Total percentage of dollars to SB: Total percentage of dollars to SB: 59%59%


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Contact DoD OSBP at 703-604-0157Contact DoD OSBP at [email protected]@osd.milOSBP web site OSBP web site http://www.acq.osd.mil/osbp/http://www.acq.osd.mil/osbp/eSRS eSRS

http://[email protected]@bta.mil and and [email protected]@esrs.gov

Defense Procurement and Acquisition Policy (DPAP)Defense Procurement and Acquisition Policy (DPAP)http://www.acq.osd.mil/dpap/pdi/eb/electronic_subhttp://www.acq.osd.mil/dpap/pdi/eb/electronic_subcontracting_reporting_system.htmlcontracting_reporting_system.html

http://www.acq.osd.mil/dpap/dars/class_deviations.http://www.acq.osd.mil/dpap/dars/class_deviations.htmlhtml

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