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Procurement Information Circular

(April 1, 1994)


PURPOSE. To provide guidance regarding the Final Subcontracting Reporting System Test Plan and Reporting Form under the Competitiveness Demonstration Program. The purpose of the test is to demonstrate whether the actual rate of small business participation on Architect-Engineer (A&E) prime contracts is substantially higher than is now being reflected in data captured by the Government's existing procurement data system. Also, this new system is intended to collect subcontracting data under a broader range of A&E contract awards than are covered by the existing reporting requirements of Public Law 95-507.

BACKGROUND: Pursuant to the Small Business Act, prime contractors and subcontractors (except small business firms) that receive one or more contracts over $500,000 ($1 million in construction) are required to submit a subcontracting plan with goals for using small business and small disadvantaged business concerns asisubcontractors under Federal prime contracts and to report accomplishments against those goals. Apparently, concerns have been expressed that the current reporting system does not provide information on the full range of participation by small business firms in the Federal procurement process. As required by Section 202(d) of the Small Business Credit and Opportunity Enhancement Act of 1992, the Administrator of the Office of Federal Procurement Policy (O.. PP) is required to develop and implement a simplified system to collect data on the participation of small business concerns (including concerns owned and controlled by socially and economically disadvantaged individuals) as other than prime contractors. The system will collect subcontract data regarding prime contractors for A&E services that are procured under the Brooks Act. This reporting system is independent of current reporting requirements under Public Law 95-507 and FAR 52.219-9, Small Business and Small Disadvantaged Business Subcontracting Plan.

On October 14, 1993, OFPP issued the enclosed Memorandum providing policy direction that established the requirement for a simplified Subcontract Reporting System under the Small Business Competitiveness Demonstration Program. Subsequently, OFPP revised the reporting form and has provided replacement pages containing technical corrections to the test plan and reporting form. These replacement pages have already been incorporated into the enclosed Memorandum. As a result of OFPP's revising the form and instruction pages, the commencement of the test was delayed. The test will now commence at NASA on April 1, 1994.

GUIDANCE. Effective April 1, 1994, the following applies:

The system shall be applicable to data collected from prime contractors that receive a contract for A&E services under the Brooks A&E Act with an anticipated value over >$100,000 and which has the possibility for subcontracting opportunities. The prime contractors shall report information on subcontract awards over $25,000 through the second tier that are directly needed for prime contract performance, irrespective of the product or service provided under the subcontract. The enclosed Form XXX shall be used to report the required information.

Subcontract awards under prime contracts in the following designated industry group arc to be reported under the system: A&E services (including surveying and mapping) under SIC codes 7389, 8711, 8712, or 8713 (limited to FPDS service codes CHI through C216, C219, T002, T004, T008, T009, T014, and R404) awarded under the Brooks A&E Act

Include the following clause in contracts and solicitations covered by the System with an estimated value over $100,000 and which have the possibility for subcontracting opportunities. The luose is not applicable to small business and small disadvantaged business firms:

(OCTOBER 1992)

(a) The Contractor shall submit it completed Form XXX in accordance with the instructions in Attachments A and B.

(b) The Contractor shall include subparagraph (a) of this clause in subcontracts with an estimated value over $25,000 awarded under this contract, excluding subcontracts with small business and small disadvantaged business firms, non-profits, educational institutions, and state and local governments. The Contractor shall also include this subparagraph (b), or its equivalent, in any such subcontract so that these requirements will be binding upon subcontracts awarded through the second tier.

(c) The Contractor shall include the prime contract number in its subcontracts and require its subcontractors through the second tier (except small business and small disadvantaged business firms, non-profits, educational institutions, and state and local governments) to include both the prime contract number and their subcontract number in their subcontracts. (Note: The prime contract number shall be the identifier used to track all subcontract activity under the prime contract.)

(End of clause)

Copies of the completed Form XXX shall be submitted to the Office of Procurement, Code HM, no later than 30 days after the end of the quarter. The first reports will be due no later thar July 30, 1994, for the quarter ending June 30, 1994.

The simplified Subcontract Reporting System shall be in effect through September 30, 1996.

EFFECTIVE DATE: - This PIC is effective as dated and automatically expires on December 3,1994, unless extended, superseded, or canceled,

HEADQUARTERS CONTAC:  Deborah O'Neill, Code HP, (202) 358-0440; Bruce King, Code HM@ (202) 358-0461; or Franz Hoffmann, Code K, (202) 358-2088.

Walker Lee Evey

Director, Procurement
Policy Division