Att J.2-3 - SPARC Small Business Participation - I&T.pdf
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- Solicitation number
- 80GRC026R0009
About this file
This is an instruction and template document for Small Business Participation requirements in response to the SPARC solicitation. The document establishes requirements for all offerors to submit a Small Business Utilization Plan demonstrating commitment to maximize small business participation during contract performance. All offerors except small businesses must additionally submit a Small Business Subcontracting Plan with proposed percentage goals and subcontracting dollar amounts across multiple small business categories including women-owned small businesses, small disadvantaged businesses, veteran-owned businesses, service-disabled veteran-owned businesses, HUBZone small businesses, and historically black colleges and universities/minority institutions.
The Small Business Utilization Plan must address work to be performed by small businesses, identification of small business subcontractors with enforceable versus non-enforceable commitments, and commitment to small business development including outreach, assistance, mentor-protégé participation, counseling, and market research procedures. The Small Business Subcontracting Plan (for non-small business prime contractors) must include proposed percentage goals based on total contract value, methodology for determining goals, and detailed plan elements required by FAR 19.704 covering principal types of supplies and services, methods for identifying sources and ensuring equitable competition, flow-down assurances, timely payment procedures, and record-keeping systems. Initial submission is due with the proposal, with approval required prior to contract award. Contractors must submit semi-annual reports and contract completion reports to NASA/GRC using the Electronic Subcontracting Reporting System (eSRS) at www.esrs.gov. The plan must be maintained throughout contract performance with updates submitted for Contracting Officer approval as changes occur to subcontracting approach or goals.
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Attachment J.2-3 SPARC Small Business Participation – Instructions and Template
Description/Use. Establish the requirements for offerors to submit a Small Business Utilization Plan and Small Business Subcontracting Plan (as applicable) in response to the SPARC solicitation. The data will be used to evaluate the offeror's commitment to maximize small business participation during contract performance, assess the reasonableness and achievability of proposed small business subcontracting goals, and determine compliance with FAR 52.219-9, Small Business Subcontracting Plan.
All offerors, including small businesses, must submit a Small Business Utilization Plan.
All offerors except small businesses must also submit a Small Business Subcontracting Plan with proposed percentage goals and subcontracting dollars.
Initial Submission. Initial – Submit with Proposal
Additional Submission. Update as required to reflect changes that affect Subcontracting implementation.
Submission Frequency:
1. Subcontracting Plan:
a. Initial – Due with proposal.
b. Approval – Prior to contract award
c. Frequency – To be updated in accordance with FAR 19.702, Statutory
Requirements
2. Reports:
a. All reports shall be submitted in accordance with Clause 52.219-9 Small Business Subcontracting Plan Alternative II NOV 2016 and NFS 1852.219-75, Individual Subcontracting Reports.
b. The contractor shall submit semi-annually and at contract completion to the NASA/GRC CO Individual Subcontract Report and Summary Reporting, using the electronic version of this data.
c. Contractors are required to submit subcontracting data in the Electronic Subcontracting Reporting System (eSRS).
d. All contractors are required to register and file bothe types of subcontracting reports using the eSRS system. The website to register is www.esrs.gov.
Format. The Contractor’s format is acceptable for the plan. Reporting shall follow NFS 1852.219-75, Individual Subcontracting Reports.
Interrelationship.
SPARC Attachment J.2-2 Version 1 – August 27, 2026
• FAR 19.702, Statutory Requirements
• FAR 52.219-9, Small Business Subcontracting Plan
• FAR 52.219-8, Utilization of Small Business Concerns
• NFS 1852.219-75, Individual Subcontracting Reports.
Applicable Documents.
• FAR Part 19, Small Business Programs
• NFS Part 1819, Small Business Programs
Scope. This requirement applies to all offerors responding to the SPARC solicitation.
The scope includes:
• For all offerors (including small businesses): Small Business Utilization Plan demonstrating commitment to maximize small business participation
• For all offerors except small businesses: Small Business Subcontracting Plan with proposed goals, methodology, and compliance with FAR 52.219-9
• For small business offerors: Small Business Utilization information to the extent subcontracting opportunities exist in their approach
The plan covers all small business categories and addresses both enforceable and non-enforceable commitments to small business subcontractors.
Contents.
A. Small Business Utilization Plan (Required for ALL Offerors, including Small Businesses)
1. Work to be Performed by Small Businesses o Brief description of work that will be performed by small businesses o Identification of any work to be subcontracted that is considered "high technology" (research and development efforts that are within or advance the state-of-the-art in technology discipline and are performed primarily by professional engineers, scientists, and highly skilled and trained technicians or specialists) o Description of potential risks or impacts to seamless performance when subcontracting out high technology efforts
2. Identification of Small Business Subcontractors o If subcontractor(s) is/are known, connect the work to the specific subcontractor o Specify the extent of commitment to use the subcontractor(s) (enforceable
vs. non-enforceable commitments) o Provide documentation regarding enforceable commitments (e.g., mentor-protégé agreement, letters of commitment, etc.) to utilize small businesses in any small business category
3. Commitment to Small Business Development o Information demonstrating the extent of commitment to utilize small business concerns and support their development o Brief description of established or planned procedures and organizational structure for:
Small Business outreach
Assistance to small businesses
Participation in the Mentor Protégé program
Counseling
Market research and Small Business identification
Relevant purchasing procedures o Discussion of how this information will support the achievement of the goals in the proposed subcontracting plan
Note for Small Business Offerors: Provide the above information to the extent subcontracting opportunities exist in your approach to performing the requirement.
B. Small Business Subcontracting Plan (Required for ALL Offerors EXCEPT Small Businesses)
Submit a complete Small Business Subcontracting Plan in accordance with FAR 52.219-9, Small Business Subcontracting Plan, including:
1. Subcontracting Goals o Proposed percentage goals for:
Small business concerns
Small disadvantaged business concerns
Women-owned small business concerns
HUBZone small business concerns
Veteran-owned small business concerns
Service-disabled veteran-owned small business concerns o Proposed subcontracting dollars by category o Goals should be based on total contract value
2. Methodology for Determining Goals o Documentation of the methodology used to determine proposed goals o Rationale demonstrating goals are based on realistic assessment of subcontracting opportunities
3. Plan Elements Required by FAR 19.704 o Description of principal types of supplies and services to be subcontracted o Identification of types of supplies or services planned for subcontracting to small business concerns, including small business categories o Methods used to develop subcontracting goals o Methods used to identify potential sources for solicitation purposes o Methods used to ensure small business concerns have an equitable opportunity to compete for subcontracts o Assurances regarding flow-down of FAR 52.219-8 to all subcontracts offering further subcontracting opportunities o Assurances that subcontractors (except small business concerns) receiving subcontracts exceeding $750,000 ($1.5 million for construction) will adopt a subcontracting plan complying with FAR 52.219-9 o Description of efforts to ensure timely payment to small business subcontractors o Description of record-keeping system to support subcontracting plan administration o Description of process for periodic review and evaluation of subcontractors' performance o Description of types of records to be maintained
4. Consideration Factors o Amount of work being retained or performed in-house by the prime contractor o Type of work proposed to be subcontracted to small businesses o Overall commitment to utilizing small businesses
Proposed Goals as Percent of Contract Value and as Percent of Subcontracting
Column A Column B Column C Business Category Goal as Percent of
Total Contract Value Dollar Value to be subcontracted per
Category
Goal as Percent of Total Subcontracting
Dollars Small Business Concerns Large Business Concerns Total Dollars to be Subcontracted
Subcategories of Small Business Concerns Woman Owned Small Business Small Disadvantaged Business Veteran Owned Business Service-Disabled Veteran Owned Small Business
HUBZone Small Business Historically Black Colleges and Universities and other Minority Institutions (HBCU/MI)
Example Contract Proposed at $100M with Estimated Subcontracts of $50M
Column A Column B Column C Business Category Goal as Percent of
Total Contract Value Dollar Value to be subcontracted per
Category
Goal as Percent of Total Subcontracting
Dollars Small Business Concerns 25% $25,000,000 50 percent Large Business Concerns n/a $25,000,000 50 percent Total Dollars to be Subcontracted n/a $50,000,000 100 percent
Subcategories of Small Business Concerns Woman Owned Small Business 9 percent $9,000,000 18 percent Small Disadvantaged Business 5.5 percent $5,500,000 11 percent Veteran Owned Business 2.5 percent $2,500,000 5 percent Service-Disabled Veteran Owned Small Business
1.5 percent $1,500,000 3 percent
HUBZone Small Business 1.5 percent $1,500,000 3 percent Historically Black Colleges and Universities and other Minority Institutions (HBCU/MI)
1.5 percent $1,500,000 3 percent
Shall be 100% if any dollars are subcontracted. ** The small business categories do not necessarily add up to the percentage and dollar amount in the “Small Business Concern” category above, since some small businesses do not fall into any of the subcategories below, while others will fall into the more than one subcategory below. It is recommended that Offerors first complete Column B by entering the dollar amount the Offeror proposes to subcontract to each business category and subcategory. To complete column A, divide the dollar amount in Column B by the total offered price of the proposal (that is, total contract value)> In the example above, Column A Veteran Owned Small Business = $2,500,000 divided by $1000,000,000 or 2.5%. To complete Column C, divide the corresponding amount in Column B by the amount in the “Total Dollars to be Subcontracted” cell in Column B. In the example above, Column C for Veteran Owned Small Business = $2,500,000 divided by $50,000,000, or 5%.
List of Small Business Subcontractors
Company Name
UEI / Cage Code
Type of Business
NAICS SOW Ref. Dollar Value
Total
Example Small Business Subcontractors
Company Name
UEI / Cage Code
Type of Business NAICS SOW Ref. Dollar Value
XYZ Corp 123456789 SB, SDB 811212 3.2 $400,000 Acme Ltd. 5WKH50 Large 541579 2.1 $1,520,000
Smith and Jones VOSB, SDVOSB 541512 2.4 $4,650,000 Total $6,570,000
Reports (Large business primes only): All reports shall be developed and submitted in accordance with 52.219-9, Small Business Subcontracting Plan and 1852.219-75 Individual Subcontracting Reports.
Remarks.
• Evaluation: The Small Business Utilization Plan and Subcontracting Plan will be evaluated under Section M, Factor MS2: SPARC Small Business Participation.
• Key Evaluation Considerations:
o Completeness, reasonableness, and soundness of the offeror's independent assessment to achieve proposed subcontracting goals o Compliance with FAR 19.704 requirements o Type of work to be performed by small businesses o Extent to which specific small business companies are named o Whether documented/enforceable commitments are demonstrated (enforceable commitments will be considered more favorably than non-enforceable ones) o Extent to which high technology work is subcontracted to small businesses and associated risks/mitigations o Extent of commitment to use small businesses and support their development o Established or planned procedures and organizational structure for small business support o How the organizational structure and procedures support achievement of goals and commitments
• Small Business Offerors: Will be evaluated only on the amount of work proposed to be performed by the small business prime and any small business subcontractors at the first-tier subcontract level. Individual subcontracting goals by small business categories will not be evaluated for small business primes and their first-tier subcontractors.
• NASA Agency-Level Goals: Provided in Attachment J.2-3 for informational purposes and consideration.
• Approval Required: All submittals and interim changes require written approval from the Contracting Officer before formal release for use or implementation.
Maintenance. The Small Business Utilization Plan and Subcontracting Plan must be maintained throughout contract performance. Changes must be submitted to the Contracting Officer for approval. Updates may be required:
• During negotiations
• At contract award (if modifications are necessary)
• As directed by the Contracting Officer during contract performance
• When there are material changes to subcontracting approach or goals
All revisions must be incorporated by complete reissue and submitted for Contracting Officer approval.
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