Federal Acquisition Regulations (FAR) requires the submission of Small Business Subcontracting Plans (SBSPs) whenever the aggregate amount of a government contract exceeds $700,000. Purchasing Services is responsible for this action under Federal Contracts; the Office of Sponsored Programs (OR) is the liaison between the department and Purchasing Services. Further details about how to develop and submit a plan can be found here and here.
- Purchasing Services is the main contact for Small Business Subcontracting Plans: e-mail: firstname.lastname@example.org.
- Proposals for any government contract expected to exceed $700,000 require the submission of a detailed SBSP, regardless of whether the project submission is in response to an unsolicited proposal opportunity, Broad Agency Announcement (BAA), or Request for Proposal (RFP).
- Purchasing Services and OR prefer to wait until sponsor asks for a SBSP.
- Purchasing Services requests OR to approve the finalized budget before Purchasing Services develops the plan. It is most efficient if your proposed budget is reviewed/approved by OR before submission to Purchasing Services. If OR finds errors in the calculations or items missing from the sponsor's request (if during the Pre-Award Revisions stage) that causes the budget to change, Purchasing Services will have to redraft the plan.
- Preparing a SBSP involves a) integrating plan opportunities into line item preparation of the proposal, b) Providing opportunities to Small, Small Disadvantaged, Woman-Owned Small, Historically Underutilized, Veteran-owned and Service Disabled Veteran-owned businesses, and c) filling out the appropriate subcontracting plan form.
After the small business subcontracting plan is made and the award is signed:
- Purchasing has oversight responsibility for preparing and submitting the data that documents actual performance in terms of dollars paid to small/disadvantaged business concerns. (See https://cfo.pitt.edu/pexpress/documents/scdirectory.pdf.)
- Purchasing will submit progress reports on small business subcontracting plan goals to the federal government or sponsor depending on the language in the Agreement via the Electronic Subcontracting Reporting System (eSRS) semi‐annually (April 30 and October 30).
- The spend data concerning subcontracting plan expenditures are obtained from the PRISM financial system by sponsored project numbers.
- To ensure that the small business subcontracting plan goals are being met, communication is essential between the department administrator and the University’s Supplier Diversity & Sustainability Coordinator or his/her designee.
- It is the responsibility of the department administrator and/or his/her designee to ensure that contract spending aligns with small business subcontracting plan goals.