CLC 059 Management of Subcontracting
Compliance Questions and Answers
Commercial Subcontracting Plan - ANSWER-A commercial subcontracting plan is a
subcontracting plan (including goals) that covers the offeror's fiscal year and that
applies to the entire production of commercial items sold by either the entire company
or a portion thereof, such as a division, plant, or product line. The commercial
subcontracting plan is the preferred plan when the contractor is furnishing commercial
items to the government. It includes the fifteen elements we'll go over shortly, but with
some variation from the requirements for the individual subcontracting plan.
Comprehensive Subcontracting Plan - ANSWER-DFARS 219.702-70 describes a test
program developed by DoD to determine whether comprehensive subcontracting plans
on a corporate, division, or plant-wide basis will reduce administrative burdens while
enhancing subcontracting opportunities for small and small disadvantaged business
concerns. This program is referred to as the Test Program for Negotiation of
Comprehensive Small Business Subcontracting Plans (Test Program).To become and
remain eligible to participate in the Test Program, a business concern is required to
have furnished supplies or services (including construction) under at least three DoD
contracts during the preceding fiscal year, having an aggregate value of at least $100
million. Test Program participants use their comprehensive subcontracting plans, in lieu
of individual subcontracting plans, when performing any DoD contract or subcontract
that requires a subcontracting plan.
Goal of Government Procurement - ANSWER-Small businesses should be provided
maximum practicable opportunities to participate in government procurements.
How will the inclusion of the flow-down clauses in CD 2018-O0021 or FAR 52.244-6
impact post-award subcontracting compliance management? For all four contracts, the
procuring contracting officer (PCO) has delegated all contract administration functions
that can be delegated. - ANSWER-It is a best practice for the administrative contracting
officer (ACO) to conduct a post-award orientation conference and review the required
flow-down clauses with the prime contractor.
During post-award administration, we need to impress upon each prime contractor that
it is the prime contractor's responsibility to ensure that its subcontractors are complying
with the flow-down clauses.
If a contract modification occurs, under what circumstances will a subcontracting plan
be required? - ANSWER-If the modification causes the contract value to exceed the
threshold in FAR 19.702, and subcontracting opportunities exist.
In order to receive a contract award, the successful offeror (the prime contractor to be)
must have an acceptable subcontracting plan. The plan may need to be negotiated to
Compliance Questions and Answers
Commercial Subcontracting Plan - ANSWER-A commercial subcontracting plan is a
subcontracting plan (including goals) that covers the offeror's fiscal year and that
applies to the entire production of commercial items sold by either the entire company
or a portion thereof, such as a division, plant, or product line. The commercial
subcontracting plan is the preferred plan when the contractor is furnishing commercial
items to the government. It includes the fifteen elements we'll go over shortly, but with
some variation from the requirements for the individual subcontracting plan.
Comprehensive Subcontracting Plan - ANSWER-DFARS 219.702-70 describes a test
program developed by DoD to determine whether comprehensive subcontracting plans
on a corporate, division, or plant-wide basis will reduce administrative burdens while
enhancing subcontracting opportunities for small and small disadvantaged business
concerns. This program is referred to as the Test Program for Negotiation of
Comprehensive Small Business Subcontracting Plans (Test Program).To become and
remain eligible to participate in the Test Program, a business concern is required to
have furnished supplies or services (including construction) under at least three DoD
contracts during the preceding fiscal year, having an aggregate value of at least $100
million. Test Program participants use their comprehensive subcontracting plans, in lieu
of individual subcontracting plans, when performing any DoD contract or subcontract
that requires a subcontracting plan.
Goal of Government Procurement - ANSWER-Small businesses should be provided
maximum practicable opportunities to participate in government procurements.
How will the inclusion of the flow-down clauses in CD 2018-O0021 or FAR 52.244-6
impact post-award subcontracting compliance management? For all four contracts, the
procuring contracting officer (PCO) has delegated all contract administration functions
that can be delegated. - ANSWER-It is a best practice for the administrative contracting
officer (ACO) to conduct a post-award orientation conference and review the required
flow-down clauses with the prime contractor.
During post-award administration, we need to impress upon each prime contractor that
it is the prime contractor's responsibility to ensure that its subcontractors are complying
with the flow-down clauses.
If a contract modification occurs, under what circumstances will a subcontracting plan
be required? - ANSWER-If the modification causes the contract value to exceed the
threshold in FAR 19.702, and subcontracting opportunities exist.
In order to receive a contract award, the successful offeror (the prime contractor to be)
must have an acceptable subcontracting plan. The plan may need to be negotiated to
