Overview of Small Business Subcontracting Plan

The Plan

A Small Business Subcontracting Plan (SBSP or Plan) is required for federal contract and subcontract awards over $750,000 total costs (or $1.5 million for construction projects), inclusive of all budget years, in accordance with Acquisition.Gov Subpart 19.7 – The Small Business Subcontracting Program FAR 52.219-9. Federal law requires recipients of federal funding over the threshold to commit to spend a percentage of the project costs with specific vendors that qualify under small business categories determined by the Small Business Administration.  

 When CSU receives such a contract, the Office of Sponsored Programs (OSP) notifies the Assistant Supplier Inclusion Program Manager/ Small Business Liaison Officer (SBLO). Procurement will review and ensure CSU makes good faith efforts to provide the maximum practicable opportunity to small business concerns. 

 An individual Plan will project the percentage of costs allocated under an award to small business concerns and make small business spend goals advised by percentage of spend federal agencies set. Once submitted, the university reports on the Plan’s compliance semi-annually. Penalties for failure to meet the Plan commitment can match the contract value. 

Procurement asks for 10 days’ notice to create a reasonable and realistic plan. The first step is for the department and the PI to fill out the SBSP outline worksheet, following the directions on the first tab. Provide the Assistant Supplier Inclusion Program Manager the SBSP outline worksheet, the Statement of Work, and the budget from Kuali Research. 

For questions, email small business: smallbusiness@colostate.edu 

Roles & Responsibilities

Principal Investigator and Campus Departments

  • Coordinate with Assistant Supplier Inclusion Program Manager/Small Business Liaison Officer (SBLO) and the campus contracts/grants office in the development of the Subcontracting Plan and any modifications;
  • Provide SBLO with the budget from Kuali Research, the Statement of Work, and the outline worksheet that describes the materials and supplies, equipment over $5,000, travel, and any services for the project for the SBLO to create the plan; 
  • Collaborate with the SBLO, the Research Administrator, and the research team to determine how the project can best meet the small business utilization goals;  
  • Notify Purchasing Agent and SBLO when a Purchase Requisition is submitted using funds within a Subcontracting Plan;
  • Maximize opportunities for small business concerns to participate in purchases within the department’s delegated authority;
  • Assist in preparation of reports as necessary;
  • Work with SBLO to ensure goals are met; and,
  • Participate in training opportunities coordinated by the SBLO, sharing information with all applicable personnel.

Sponsored Programs

  • Notify SBLO as soon as an RFP is received that includes the requirement for a Small Business Subcontracting Plan;
  • Coordinate with SBLO and the campus department (e.g., Principal Investigator) in the development of the Subcontracting Plan and any modifications;
  • Provide SBLO with Small Business Subcontracting Plans upon their approval by the contracting officer;
  • Ensure that SBLO is notified immediately upon notification that a Small Business Subcontracting Plan is required;
  • Ensure that SBLO is notified if there is a contract number change;
  • Work with SBLO to assist department in identifying potential small business concern subcontractors to be named in the proposal;
  • Endorse official proposal, thereby endorsing the Small Business Subcontracting Plan; and,
  • Participate in departmental training coordinated by SBLO. 

Procurement

  • Maximize opportunities for small business concerns to compete for University business, regardless of funding source;
  • On applicable solicitations, work with SBLO to ensure adequate inclusion of small business concerns in solicitation process, including using CCR/PRO-Net and other available sources;
  • Participate in vendor outreach (e.g., informational meetings, vendor fairs) as requested;
  • Work with SBLO to identify small businesses and recognizing those small businesses for effort where applicable;
  • Assist in identifying Purchase Requisitions using funds governed by a Small Business Subcontracting Plan;
  • Assist in identifying Purchase Requisitions using federal contract funds where a Small Business Subcontracting Plan may be required of the vendor, and coordinate such plans with SBLO; and,
  • Participate in training coordinated by SBLO.

Small Business Liaison Officer (SBLO)

  • Submit, in a timely manner, the required forms (ISR and SSR) to applicable agencies;
  • Work with Sponsored Programs Office to identify proposals where a Small Business Subcontracting Plan is required, and complete Plan in a timely manner;
  • Maintain vendors in Kuali in the supplier diversity field to enable accurate reporting;
  • Source vendors that can be used to achieve subcontracting plan goals;
  • Create outreach and training activities to educate all involved parties as to their roles and responsibilities;
  • Work with Purchasing Agents on applicable solicitations to ensure adequate involvement of small business concerns;
  • Work with Purchasing Agents and vendors to attain a Small Business Subcontracting Plan where required;
  • Provide opportunities for vendors to learn how to do business with the University (e.g., sharing information on BIDS, key department contacts, Purchasing Agent contacts, etc.); and,
  • Provide incentives and recognition opportunities for Purchasing Agents accomplishment toward the goals is not taking place, so purchases can be made with the small businesses included in the plan.