ATT 9_SB SubK Plan Template 1.19.22.docx

ATTACHMENT 9

U.S. OFFICE OF PERSONNEL MANAGEMENT

SMALL BUSINESS SUBCONTRACTING PLAN

The following outline meets the minimum requirements of Section 8(d) of the Small Business Act (15 U.S.C. 637(d)) and the Federal Acquisition Regulation (FAR) Subpart 19.7. It is intended to be a guideline. It is not intended to replace any existing corporate plan which is more extensive. If assistance is needed to locate small business sources, contact the Small Business Administration (SBA). Please note that for Fiscal Year 2022, the U.S. Office of Personnel Management (OPM) has the following subcontracting goals:

25.0% for all small businesses, 5.0% for small disadvantaged business, 5.0% for women-owned small business, 3.0% for HUBZone small business, and 3.0% for service-disabled, veteran-owned small business concerns.

Identification Data:

Company Name: Address: Date Prepared: Solicitation Number: 24361821R0002 Item/Service: Benefits Enrollment and Premium Administration Services for BENEFEDS Program Place of Performance:

1. TYPE OF PLAN: (Check only one).

2. GOALS:

FAR 19.704(a)(1) requires separate dollar and percentage goals for using small business, veteran-owned small business, service-disabled veteran-owned small business, HUBZone small business, small disadvantaged business, and women-owned small business concerns for the base year and each option year. (Please note that the goals for veteran-owned small business, service-disabled veteran-owned small business, HUBZone small business, small disadvantaged business, and women-owned small business concerns are sub-sets of the small business goal).

A.

Estimated dollar value and percentage of all planned subcontracting, i.e., to all types of business concerns under this contract is:

Start Up Period

Base Year One

Base Year Two

Base Year Three

Option Year One

B. Estimated dollar value* and percentage of planned subcontracting to small business concerns is:

(*This figure includes the amount in C, D, E, F, and G below.)

Start Up Period

Base Year One

Base Year Two

Base Year Three

Option Year One

C. Estimated dollar value and percentage of planned subcontracting to HUBZone small business concerns is:

Start Up Period

Base Year One

Base Year Two

Base Year Three

Option Year One

D. Estimated dollar value and percentage of planned subcontracting to small disadvantaged business concerns is:

Start Up Period

Base Year One

Base Year Two

Base Year Three

Option Year One

E.

Estimated dollar value and percentage of planned subcontracting to small women-owned business concerns is:

Start Up Period

Base Year One

Base Year Two

Base Year Three

Option Year One

F. Estimated dollar value and percentage of planned subcontracting to veteran- owned small business concerns is:

Start Up Period

Base Year One

Base Year Two

Base Year Three

Option Year One

G. Estimated dollar value and percentage of planned subcontracting to service disabled veteran-owned small business concerns is:

Start Up Period

Base Year One

Base Year Two

Base Year Three

Option Year One

H. Supplies and/or services to be subcontracted under this contract, business size (i.e., SB, HUBZone, SDB, WOSB, VOSB, SDVOSB, and LB), and the estimated dollar expenditure, are: (Check all that apply).

(Add additional rows / sheets as necessary.)

I.

Explain the methods used to develop the subcontracting goals for small, HUBZone small business, small disadvantaged, women-owned small business, veteran-owned small business, and service-disabled veteran-owned small business concerns. Explain how the product and service areas to be subcontracted were established, how the areas to be subcontracted to small, HUBZone small business, small disadvantaged, women- owned small, veteran-owned small business, and service disabled veteran- owned small businesses were determined, and how the capabilities of small, HUBZone small, small disadvantaged, women-owned small, veteran-owned and service disabled veteran-owned small businesses were determined. Identify all source lists used in the determination process.

J. Indirect and overhead costs

HAVE BEEN

HAVE NOT BEEN

included in the dollar and percentage subcontracting goals stated above. (Check one.)

K. If indirect and overhead costs HAVE BEEN included, explain the method used to determine the proportionate share of such costs to be allocated as subcontracts to small, HUBZone small, small disadvantaged, women-owned small, veteran-owned, and service disabled veteran-owned small business concerns.

3.

PLAN ADMINISTRATOR:

FAR 19.704(a)(7) requires information about the company employee who will administer the subcontracting program. Please provide the name, title, address, phone number, position within the corporate structure and the duties of that employee.

Name:

Title:

Address:

Telephone:

Fax:

Email Address:

Position:

Duties: Does the individual named above perform the following? (If NO is checked, please indicate who in the company performs those duties, or indicate why the duties are not performed in your company).

A. Developing and promoting company/division policy statements that demonstrate the company's/division's support for awarding contracts and subcontracts to small, HUBZone small, small disadvantaged, women-owned small, veteran-owned, and service disabled veteran-owned small business concerns.

YES NO

B. Developing and maintaining bidders' lists of small, HUBZone small, small disadvantaged, women-owned small, veteran-owned small, and service disabled veteran-owned small business concerns from all possible sources.

YES NO

C. Ensuring periodic rotation of potential subcontractors on bidders' lists.

YES NO

D. Assuring that small, HUBZone small, small disadvantaged, women-owned small, veteran-owned small, and service disabled veteran-owned small businesses are included on the bidders' list for every subcontract solicitation for products and services they are capable of providing.

YES NO

E. Ensuring that subcontract procurement "packages" are designed to permit the maximum possible participation of small, HUBZone small, small disadvantaged, women-owned small, veteran-owned small, and service disabled veteran-owned small businesses.

YES NO

F. Reviewing subcontract solicitations to remove statements, clauses, etc., which might tend to restrict or prohibit small, HUBZone small, small disadvantaged, women-owned small, veteran-owned small, and service disabled veteran-owned small business participation.

YES NO

G. Ensuring that the subcontract bid proposal review board documents its reasons for not selecting any low bids submitted by small, HUBZone small, small disadvantaged, women-owned small, veteran-owned small, and service disabled veteran-owned small business concerns.

YES NO

H. Overseeing the establishment and maintenance of contract and subcontract award records.

YES NO

I. Attending or arranging for the attendance of company counselors at Business Opportunity Workshops, Minority Business Enterprise Seminars, Trade Fairs, etc.

YES NO

J. Directly or indirectly counseling small, HUBZone small, small disadvantaged, women-owned small, veteran-owned small, and service-disabled veteran-owned small business concerns on subcontracting opportunities and how to prepare responsive bids to the company.

YES NO

K. Providing notice to subcontractors concerning penalties for misrepresentations of business status as small, HUBZone small, small disadvantaged, women-owned small, veteran-owned small, or service disabled veteran-owned small business for the purpose of obtaining a subcontract that is to be included as part or all of a goal contained in the contractor's subcontracting plan.

YES NO

L. Conducting or arranging training for purchasing personnel regarding the intent and impact of Public Law 95-907 on purchasing procedures.

YES NO

M. Developing and maintaining an incentive program for buyers which supports the subcontracting program.

YES NO

N. Monitoring the company's performance and making any adjustments necessary to achieve the subcontract plan goals.

YES NO

O. Preparing and submitting timely reports.

YES NO

P. Coordinating the company's activities during compliance reviews by Federal agencies.

YES NO

4.

EQUITABLE OPPORTUNITY

FAR 19.704(a)(8) requires a description of the efforts your company will make to ensure that small business, veteran-owned small business, service-disabled veteran-owned small business, HUBZone small business, small disadvantaged business, and women-owned small business concerns will have an equitable opportunity to compete for subcontracts.

(Check all that apply.)

A. Outreach efforts to obtain sources:

B. Internal efforts to guide and encourage purchasing personnel:

C. Additional efforts: (Please describe.)

5. CLAUSE INCLUSION AND FLOW DOWN

FAR 19.704(a)(9) requires that your company include FAR 52.219-8, "Utilization of Small Business Concerns", in all subcontracts that offer further subcontracting opportunities. Your company must require all subcontractors, except small business concerns, that receive subcontracts in excess of $550,000 ($1,000,000 for construction) to adopt and comply with a plan similar to the plan required by FAR 52.219-9, "Small Business Subcontracting Plan."

Your company agrees that the clause will be included and that the plans will be reviewed against the minimum requirements for such plans. The acceptability of percentage goals for small business, veteran-owned small business, service-disabled veteran-owned small business, HUBZone small business, small disadvantaged business, and women-owned small business concerns must be determined on a case-by-case basis depending on the supplies and services involved, the availability of potential small business, veteran-owned small business, service-disabled veteran-owned small business, HUBZone small business, small disadvantaged business, and women-owned small business subcontractors and prior experience. Once the plans are negotiated, approved, and implemented, the plans must be monitored through the submission of periodic reports, including Standard Form (SF) 294 and SF 295 reports.

6.

REPORTING AND COOPERATION

FAR 19.704(a)(10) requires that your company (1) cooperate in any studies or surveys as may be required, (2) submit periodic reports which show compliance with the subcontracting plan; (3) submit Standard Form (SF) 294, "Subcontracting Report for Individual Contracts," and SF 295, "Summary Subcontract Report," in accordance with the instructions on the forms; and (4) ensure that subcontractors agree to submit SF 294 and SF 295. The Contracting Officer must receive the report(s) within 30 days after the close of each calendar period. That is:

NOTE: The 294 and 295 reports must also be entered in the Electronic Subcontracting Reporting System, available online at http://www.esrs.gov.

7. RECORDKEEPING

FAR 19.704(a)(11) requires a list of the types of records your company will maintain to demonstrate the procedures adopted to comply with the requirements and goals in the subcontracting plan. (Check all that apply.)

(If NO is checked, please indicate why these types of records are not maintained).

A. Small, HUBZone small, small disadvantaged, women-owned small, veteran- owned small, and service disabled veteran-owned small business concern source lists, guides, and other data identifying such vendors.

YES NO

B. Organizations contacted for small, HUBZone small, small disadvantaged, women- owned small, veteran-owned small, and service disabled veteran-owned small business sources.

YES NO

C. On a contract-by-contract basis, records on all subcontract solicitations over $100,000 which indicate for each solicitation

(1) whether small business concerns were solicited, and if not, why not;

(2) whether HUBZone small business concerns were solicited, and if not, why not;

(3) whether small disadvantaged business concerns were solicited, and if not, why not;

(4) whether women-owned small business concerns were solicited, and if not, why not;

(5) whether veteran-owned small business concerns were solicited, and if not, why not;

(6) whether service disabled veteran-owned small businesses were solicited, and if not, why not; and

(7) reasons for the failure of solicited small, HUBZone small, small disadvantaged, women-owned small, veteran owned small, and service disabled veteran-owned small business concerns to receive the subcontract award.

YES NO

D.

Records to support other outreach efforts, e.g., contacts with minority and small business trade associations, attendance at small and minority business procurement conference and trade fairs.

YES NO

E. Records to support internal activities to

(1) guide and encourage purchasing personnel, e.g., workshops, seminars, training programs, incentive awards; and

(2) monitor activities to evaluate compliance.

YES NO

F. On a contract-by-contract basis, records to support subcontract award data including the name, address and business size and ownership status (HUBZone, SDB, WOB, VOSB, SDVOSB, etc.) of each subcontractor. (This item is not required for company or division-wide commercial plans.)

YES NO

G. Other records to support your compliance with the subcontracting plan: (Please describe)

8. TIMELY PAYMENTS TO SUBCONTRACTORS

FAR 19.702 requires your company to establish and use procedures to ensure the timely payment of amounts due pursuant to the terms of your subcontracts with small business concerns, HUBZone small business concerns, small disadvantaged business concerns, women-owned small business concerns, veteran-owned small business concerns, and service disabled veteran-owned small business concerns.

Your company has established and uses such procedures:

YES NO

RFP 24368121R0002 BENEFEDS

9. DESCRIPTION OF GOOD FAITH EFFORT

Maximum practicable utilization of small, HUBZone small, small disadvantaged women- owned small, veteran-owned small, and service disabled veteran-owned small business concerns as subcontractors in Government contracts is a matter of national interest with both social and economic benefits. When a contractor fails to make a good faith effort to comply with a subcontracting plan, these objectives are not achieved, and 15 U.S.C.

637(d)(4)(F) directs that liquidated damages shall be paid by the contractor. In order to demonstrate your compliance with a good faith effort to achieve the small, HUBZone small, small disadvantaged, women-owned small, veteran-owned small, and service disabled veteran-owned small business subcontracting goals, outline the steps your company plans to take. These steps will be negotiated with the contracting officer prior to approval of the plan.

10. SIGNATURES REQUIRED