Commercial Subcontracting Plan TEMPLATE and Instructions.doc
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v2022-September
MODEL COMMERCIAL SUBCONTRACTING PLAN TEMPLATE INSTRUCTIONS
Use the Commercial Subcontracting Plan Template when:
The company determines this is the best type of plan to meet its purchasing model and is unable to break out subcontracting attributable to a particular government contract The supplies or services provided to the federal government meet the definition of “commercial” in FAR part 2
NOTE: The Model Commercial Subcontracting Plan template is a tool contractors may choose to use when preparing their commercial subcontracting plans. The Model Commercial Subcontracting plan:
Is NOT a fill-in-the-blank form
| Does not replace the FAR requirements listed in clause 52.219-9 |
| Reflects objectives EXIM encourages contractors to adopt |
A COMMERCIAL SUBCONTRACTING PLAN
| Includes the Offeror’s (or Contractor’s) planned subcontracting supporting both commercial AND government business, rather than solely to a single government agency or contract |
| Is the preferred type of subcontracting plan for Contractors furnishing commercial items and services. However, if the contract will be a multiple award, indefinite delivery-indefinite quantity contract where task/delivery orders will be funded by more than one federal agency, consider using the individual subcontracting plan. |
| Covers only the company’s fiscal year (12-month period - i.e., only one commercial plan per Contractor annually). |
| Applies to the purchasing to support the entire production of commercial items sold by the entire company or is limited to a portion thereof (e.g. division, plant, or product line). Please indicate such a statement in the commercial plan, whether it applies company-wide or is a limited plan. |
| Must include indirect costs (i.e., general and routine commercial purchases) |
| Note: If the commercial plan encompasses more than one company within the corporation, identify in the plan the companies covered and include the UEI number for each. |
| Remains in effect during the Contractor’s fiscal year for all Government contracts in effect during that period. Once a Contractor’s commercial plan has been approved, the Government shall not require another subcontracting plan from the same Contractor while the plan remains in effect, as long as the product or service being provided continues to meet the definition of a commercial item. |
| To submit a commercial plan: |
| Complete Section I. Identification Data in the Model Template and check “Commercial Plan” under Section II, Type of Plan |
List the annual goals (or spend) for each socio-economic category listed in the commercial plan format provided under Section III, Goals.
Complete Sections IV through XV, ensuring a company official sign the plan under XVII.
| Submit the commercial plan to either: |
| the first Contracting Officer (of any agency) awarding a contract subject to the plan during the Contractor’s fiscal year; or, |
| if the Contractor has ongoing contracts with commercial plans, to the Contracting Officer responsible for the contract with the latest completion date. |
What happens after I submit the subcontracting plan to the contracting officer?
The Contracting Officer:
| Reviews the subcontracting plan to ensure the plan meets all of the requirements listed in FAR 52.219-9 |
| Submits the plan to the Small Business Administration Procurement Center Representative (PCR) for input as required by FAR |
| Considers the recommendations by the SBA PCR and negotiates the commercial plan on behalf of the entire federal government. |
Once approved by a government contracting officer, the contractor may use the commercial plan for any federal government contract during the 12-month period covered by the plan.
AFTER CONTRACT AWARD, DON’T FORGET TO:
Submit a new commercial plan, 30 working days before the end of the Contractor’s fiscal year (i.e., plan expiration date) to the Contracting Officer responsible for the uncompleted Government contract with the latest completion date.
When the new commercial plan is approved each year, provide a copy of the approved plan to each Contracting Officer responsible for ongoing contract(s) subject to the plan.
After award, submit the required annual Summary Subcontracting Report (SSR) in the Electronic Subcontract Reporting System (eSRS):
Due no later than October 30 each year. Failure to submit the report on time may indicate a lack of “good faith effort”, putting your company at risk for the assessment of liquidated damages.
Follow the directions on the eSRS home page, especially the “Quick Reference Guides for Government Contractors Filing SSR for Commercial Plan” and the Sample SSR Step by Step for Commercial plans
| Be sure to select “Commercial” as the type of subcontracting plan |
| While the commercial plan covers your company’s fiscal year, the SSR covers all subcontracting done during the government’s fiscal year (October 1 through September 30) |
| List the email address of the contracting officer who approved the commercial plan on behalf of all federal agencies and the |
contracting officers when other federal agencies’ contracts are covered by the plan
| Include indirect costs |
| Explain in the “Remarks” section any shortfall or “0” dollars reported and the corrective action going forward. Make sure the reasons or future actions are not the same year after year with no improvement. |
| Allocate to each federal agency a portion of each of the dollars reported |
| At no time should the total percentage allocated to the federal agencies equate to 99%! |
| When the government’s share is less than one percent, make sure the percentage is translated into the report correctly. For example, if the government’s allocation is 0.51%, make sure the percentage is entered as 0.51% and not 51%. |
I am having difficulty in meeting the goals established in the contract’s subcontracting plan. What should I do?
A number of actions can be taken:
| Read the plan. Did you do what you said you were going to do in the plan to find qualified SB, SDB (including *(8(a)s, ANCs, and Indian tribes), WOSB, SDVOSB, or HUBZone, and other socioeconomic concerns? | |
| Did a key small business supplier grow into “other than small”? Explain any “0” or shortfalls in the “Remarks” section of the report. Be sure to identify what corrective action you will take to get back on track. “Tell the story” in the report. | |
| Did you post your company’s subcontracting opportunities on the SBA SubNet |
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