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STEP Agency OSBP Acquiring Activity Benefit / Rationale
Participation Plan constitutes a narrative description of: Structure full and open solicitations Opportunities exist for breakout
(1) The extent to which such firms are specifically and evaluation criteria that and set-asides for small business.
identified in proposals; (2) The extent of commitment to encourage teaming with small
use such firms (for example, enforceable commitments are businesses and aggressive small Establishing subcontracting
more convincing than non-enforceable ones); (3) The business subcontracting. goals in relation to the contract’s
complexity and variety of the work small firms are to When there is a significant total dollar value rather than in
perform; (4) The realism of the proposal; (5) The extent of opportunity for subcontracting, in a relation to the prime contractor’s
participation of such firms in terms of the value of the total full and open solicitation, include a planned subcontract dollars may
acquisition (proposed subcontracting dollars/percentages). factor to evaluate past enhance small business
performance, assessing the extent to subcontracting opportunities.
The Participation Plan addresses SOW and CDRL which the offeror attained
applicable goals for small business Establishes an enforceable plan for
requirements, and Small Business Participation participation under contracts that
Goals. required subcontracting plans and small business participation and
a factor to evaluate proposed small documents prime contractor’s
business participation . commitment to use small business in
performance of the contract.
3 Participate as Small Business Advisor / Evaluator for Give greater evaluation credit to Demonstrates OSBP commitment to
Source Selection and Past Performance Team. offerors that have details to support the acquisition team and provides a
an effective participation plan and common set of principles and
identified, by name, protégé firms, procedures for evaluating the extent of
small business teaming partners, small business participation.
joint ventures, or other small
business subcontractors in their
proposals. Consider requiring
offerors (large businesses) to submit
previous eSRS reports to
demonstrate their performance in
subcontracting to small businesses.
4 Provide language to develop Award or Incentive Fee Consider establishing an award fee Consider using quantitative award
Plans (reward exceeding requirements of the or other incentive that rewards fee evaluation factors.
Participation Plan). contractors for meeting and
exceeding goals in subcontracting 2
or participation plans.
STEP Agency OSBP Acquiring Activity Benefit / Rationale
Incentive Fee Language Examples: Consider the exercise of an option to
Consider incentives that might Supports developing a competitive
Incentive Fee Language Examples: motivate prime contractors to environment by growing the
1). This Critical Performance Objectives has a Small provide substantial capabilities of small businesses, better
Business Utilization prerequisite requirement to be eligible subcontracting opportunities to enabling them to participate in follow-
for any of the performance incentive. The contractor shall small businesses. on acquisitions and serve as additional
use a small business source(s) to manufacture at least two
mission or safety critical items. The contractor shall provide sources to satisfy future requirements.
objective evidence that the small business source(s) has Consider the exercise of an option
successfully passed the quality and testing standards to extend the term of the contract
required to become an approved source in accordance with being contingent on the
the MDA Parts, Materials, and Processes Mission Assurance achievement of identified
Plan . aggressive small business
Subcontracting / Participation
2). To be eligible for the O&S performance incentives. Small Plan goals.
Business participation, by at least the percentage of
participation set forth in the Small Business Participation
and Commitment Plan, shall contribute to the achievement
of the required weapon system Scheduled and Operational
Availability performance levels.
5 Provide language to establish small business utilization Negotiate an aggressive This requires knowledge of the
as a SOW performance requirement Subcontracting / contractor, the industry, and the
Participation Plan with the activity’s small business goals. The
SOW Paragraph Example: prospective prime contractor. contracting officer should obtain
The contractor shall implement a Small Business information available from the
Participation and Commitment Plan to provide cognizant contract administration
office and evaluate the offeror’s past
maximum practicable opportunities for small business performance in awarding small
participation in the performance of the contract and business subcontracts for the same or
submit semiannually CDRL XXX to the Missile Defense similar products or services. The
Agency Office of Small Business Programs (MDA/SB). contracting officer also must notify
the SBA PCR of the opportunity to
review the proposed subcontracting
plan.
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STEP Agency OSBP Acquiring Activity Benefit / Rationale
When feasible (services
acquisitions), include language in
the solicitation that requires the
prime contractor to direct a certain
percentage of each labor category
to small businesses.
6 Provide language to establish CDRL (reporting results Ensure that the solicitation and Aside from the standard subcontract
of compliance with the small business SOW requirement contract address the method for plan reporting requirements, the
and Participation Plan). monitoring small business prime contractor should be required
performance. to address performance toward its
CDRL Example: small business Participation Plan
Report actual achievements relative to proposed small goals and objectives in any planned
business participation plan (including periodic program reviews.
subcontracting dollars / percentages), and the
results of efforts to:
(1)Expand pool of qualified small businesses through
increased competition for production of components,
parts (includes hardware and software), and to Ensure that an acceptable In accordance with FAR 19.705-7,
perform sustainability services subcontracting or participation ensure that the solicitation and
(2)Engage small businesses to serve as second sources in plan is incorporated into, and made contract (if applicable) provide for
order to mitigate the risks of single point failures in the a material part of, the contract. liquidated damages when the
supply chain and increase the quality of supplies or contractor fails to make a good-faith
services effort to comply with its
(3)Leverage Small Business Innovation Research and subcontracting / participation plan.
Small Business Technology Transfer program funded
technologies with high potential for transition
Post-Award Strategies
7 Review CDRL submissions. Regularly monitor the prime Monitor goal attainment and enforce
contractor’s subcontracting the plan requirements. This strategy
performance as provided in the ensures there are no surprises at the
Review Program Level and Quarterly Activity contract. end of the period of performance.
reports from DCMA. Consider having tele conference or It is important to have not only the
face-to-face meetings with prime contractor’s small business
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STEP Agency OSBP Acquiring activity Benefit / Rationale
Use results documented in reports to provide PCOs and representatives from the prime representative, but also a senior
CORs with commentary on large prime contractor’s contractor. member of its project management
small business utilization performance for award fee and organization, in attendance at each
incentive fee, as well as CPARS. meeting. This signals the importance
of meeting subcontracting goals to
the large business prime contractor.
The contracting officer should
request a subcontracting report if
another organization (DCMA) has
responsibility for monitoring
subcontracting plan performance.
In the early stages of the contract, More dialogue—early on—will
consider meeting frequently (e.g., provide the prime contractor an
monthly) to ensure that the prime opportunity to improve performance,
contractor gets off to a good start if necessary, before final appraisals
to-ward meeting subcontracting are given. Report progress (or lack
goals. thereof) to the contractor’s senior
management. This strategy helps
ensure that the prime contractor
starts off on the right footing.
Requiring a substitution This strategy guards against “bait
letter that spells out the prime and switch,” a practice that occurs
contractor’s rationale for any when a large contractor names a
anticipated changes from small small business in its proposal and
businesses that are identified by then releases the business after
name in the offeror’s proposal. award.
Use the Contractor Performance The CPARS offers a consistent
Assessment Reporting System means for tracking a contractor’s
(CPARS) to document the performance in meeting small
contractor’s performance in small business subcontracting /
business subcontracting. participation plans goals and
makes this information easily
accessible to other contracting
officers.
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This strategic approach to maximizing small business participation in MDA acquisitions by
implementing a comprehensive Participation Plan has been successful in integrating the
different aspects of our small business program (Outreach, Subcontracting, Mentor Protégé,
SBIR/STTR). The approach enables these programs to add greater value to MDA acquisitions.
Documents to support implementing a Small Business Participation Plan are available at:
https://acc.dau.mil/CommunityBrowser.aspx?id=723192&lang=en-US
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