18. Supplier Inclusion Program
I. General
A. The intent of the program is to provide small business concerns an equitable opportunity to compete for university business.
B. The program assists the university community and encourages the utilization of small and diverse businesses and to ensure compliance with applicable federal regulations.
C. Small business concerns are defined by the Small Business Administration and are subject to change. Current definitions are at https://www.sba.gov/
D. The program champions sustainability, which includes a stated intent to spend with local, small, and diverse business to support positive social and economic impacts.
II. Policies
A. Procurement Services is designated as the Small Business Liaison Office for the Small Business and Supplier Inclusion Program with the following responsibilities:
1. Appoint a Small Business Liaison Officer (SBLO) to oversee the program and interact with the Small Business Administration on small business compliance and reporting.
2. Identify small business concerns use by the university and maintain a list of vendors.
3. Establish and implement procedures to be followed when a small business subcontracting plan is required, following regulatory requirements and guidance (including the Small Business Administration’s Handbook for Small Business Liaison Officers).
4. Coordinate activities between Procurement Services, the Principal Investigator (PI), department/laboratory administrator, and research administrator to ensure timely submission of meaningful and appropriate Plans.
5. Establish goals for the utilization of small business concerns on research contracts when required and monitor the progress towards those goals.
6. Maintain records and reports of compliance with and accomplishments under sponsor-approved plans as of March 31st and September 30theach year or as required by the SBA. The SBLO is responsible for submitting reports to the SBA and sponsor agencies, as required. These include the Individual Subcontract Reports (ISRs) and Summary Subcontract Reports (SSRs) that are submitted through the Electronic Subcontracting Reporting System (eSRS). This also includes final MBE/WBE reports for EPA grants over the simplified acquisition threshold.
7. Submit reports of compliance and accomplishments under approved subcontracting plans to PIs, Subcontracting Plan Administrators, and cognizant Institute personnel.
8. Prepare and submit required reports of accomplishments under approved subcontracting plans to the contracting agencies.
9. Maintain relationships with and explain CSU’s procedures to small business concerns.
10. When small business concerns are identified as potential suppliers, suggest them to major contractors to develop new contractual arrangements for second-tier suppliers.
11. Connect small business concerns to relevant purchasing agents and procurement opportunities on campus.
12. Evaluate procurement processes and find methods to increase equitable opportunity for small concerns, for example, developing courtesy notice lists of small and diverse suppliers for purchasing agents or updating questionnaires used in RFPS’s around small business concerns and sustainability.
13. Continuous outreach to external organizations, such as economic development groups, Chamber of Commerce’s, national councils, and trade fair and expos, as well as sharing information and training to the university regarding supplier inclusion.
III. Procedures for Small Business Subcontracting Plan
A. The research administrator working in a pre-award capacity or the senior research administrator working in a post-award capacity of the Office of Sponsored Programs (OSP) determines, sometimes in consultation with Principal Investigator (PI) and granting agency, if a subcontracting plan is required on a federal contract. Additionally, the Small Business Liaison Officer will review an internal report monthly to ensure that contracts over $750,000 have a related plan, as sometimes modifications on a research project lead to a budget going over the threshold.
B. When it is determined a plan is necessary, the Principal Investigator (PI) and the department administrator is notified by OSP, and they are put in contact with the SBLO. The PI and department administrator return the plan outline worksheet, the statement of work, and the project budget. The following methods are used to develop the subcontracting goals:
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- Identification of all major requirements from the Statement of Work
- Analysis of current supplier diversity subcontracting accomplishments
- Analysis of make or buy decisions
- Analysis of indirect cost elements with subcontracting potential
- Identification of direct services and supplies
- Identification of those items that can successfully be set aside for small business acquisitions
- Identification of suppliers’ small business certification status through sam.gov and/or valid self-certification forms, keeping all certifications on file with the plan
C. Salaries and benefits of employees are excluded from the SBSP per (13CFR125.3(a)(1)(iii)), as are other employee benefits; payments for petty cash; depreciation; interest; income taxes; property taxes; lease payments; bank fees; fines, claims, and dues; Original Equipment Manufacturer relationships during warranty periods (negotiated up front with product); utilities such as electricity, water, sewer, and other services purchased from a municipality or solely authorized by the municipality to provide those services in a particular geographical region; and philanthropic contributions. Utility companies may be eligible for additional exclusions unique to their industry, which may be approved by the contracting officer on a case-by-case basis.
Exclusions from the subcontracting base include but are not limited to those listed above. Colorado State University does not include indirect costs in establishing small business goals for subcontracting plans. The estimated individual goals and percentages of an individual plan will cover the entire contract period with goals and percentages, based on the planned purchases of products and services needed to maintain this specific solicitation/federal contract. Vendors are verified by the SBLO through Sam.gov during the creation of the project and ongoing as the project continues as new sourcing needs arise.
D. The SBLO maintains a list of all internal accounts with subcontracting plans and shares those with the Purchasing Agents. When a procurement on one of these accounts enter procurement’s queue, the SBLO and Purchasing Agent work together to source small business concerns. The SBLO will then work with PI to find an agreed upon vendor. Notes are made within the Requisition (REQ) in the Kuali Financial System to outline efforts made to identify small business concerns.
E. The SBLO will run monthly reports to monitor progress on research contracts with small business subcontracting plans. The SBLO will run a monthly report to review all university contracts to evaluate if projects have gone over the threshold, and to review EA grants over $250,000. Detailed information on the administrative processes is outlined in the Supplier Inclusion Procedure Manual.