Best Practices for Achieving Subcontracting Goals and How SBs can Leverage the Subcontracting Program

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1 Best Practices for Achieving Subcontracting Goals and How SBs can Leverage the Subcontracting Program Shawn Ralston SB Program Manager National Governments AECOM May 10, 2018

2 SB Participation vs. SB Subcontracting Governing Regulations (FAR.704 and FAR /DFARS ) SB Goals o Subcontract value goals required contract value goals may be requested. o Must be consistent with the SBPP in proposal Dollars must match-up which can be tough if given both subcontract value and contract value goals o Goals may be required by TO for IDIQs but only 1 SBSP can be required o Reporting is now required by task orders for contract used by multiple agencies Approvals Scoring o Client approves as well as SBA o Plan must be received and approved prior to award o Acceptable/Unacceptable opportunity to fix plan usually provided o Must included all FAR Elements to be found acceptable Note: SBSP are not required by Small Businesses 2

3 SB Participation vs. SB Subcontracting SB Participation Criteria for Evaluation (DFAR (c)(i)(A) PGI) The extent of participation of SB firms in terms of the value of the total acquisition and the extent of which the proposals meets or exceeds small business participation goals for this acquisition. o Strength (+) meets all minimums, significantly exceeds one or more, supporting market research o Strength meets all minimums, supporting market research o Weakness when only a SB minimum is required: meets SB overall minimum, does not address other goals (SDB, HZ, WOSB, SDVOSB), OR no market research o Deficiency does not address any of the specified minimum goals The extent to which SB firms are specifically identified in proposals; o Strength (+) identified by name w/ redundancy in all goals multiple lists corresponding to various TO scenarios and tied to specific work o Strength identified by name and tied to specific work o Weakness some not identified or linked to specific work, unclear linkage o Deficiency SB firms not identified by name only SB category The complexity and variety of the work small firms are to perform; o Strength (+) all significant work designated for SB o Strength most significant work designated for SB o Weakness insufficient significant work designated for SB o Deficiency only insignificant work designed for SB 3

4 Proposal Submissions AECOM seeks to name specific SBs whenever possible to show clients we are committed to utilizing SBs and to line up the right SB support for each contract Keep in mind that to list specific SBs by name, you must have written permission to do so from any the firm. (CFR Title (c)(8)) Firms that are named in the proposal must be tracked and reported on at the end of the contract if they did not receive any work or less work than specified in the submission. (FAR (d)(13) In some cases, we are asked to estimate participation by firm but this is very difficult on an IDIQ contract. It is very common for solicitations to request Individual Subcontract Reports (ISRs) or CPARs to validate that we have a history of meeting goals and providing maximum practicable opportunity for SBs to support us on our work We have also been asked to provide subcontracting data on projects that we are submitting to show we utilize SBs in our work. CPARs are sometimes rated N/A even when a subcontracting plan is in place at the contract level. We make a concerted effort to correct this evaluations to reflect our performance 4

5 Small Business Goals We seek to set reasonable and obtainable SB goals based on the expected work and availability of SBs to support the work When SB goals are provided, we seek to identify SB firms in the various categories that will allow us to meet all goals by contract completion SB Participation plan and Subcontracting plan goals must be consistent We work through both sets of goals even if both are not required at the same time Primes are now required to assign NAICS codes so it is a best practice to identify the intended NAICS code and verify that firm is in fact a SB (verifying through SAM). Separate SB goals at the TO level & Reporting at the TO level Order Reporting: IDIQs intended for use by multiple agencies FAR (d)(10) (iii) TO Goals: Contracting Officers may establish SB goals for each order (FAR (e)) There can be two sets of goals. PMs must understand the difference and plan to meet both sets of goals. We are held to meeting both. A report is due at the end of the contract to explain why goals were not met this is in addition to the explanation required on each ISR over the period of performance. 5

6 Efforts to Promote SB & Meet Goals SB Performance Reviews We hold one-on-one sessions with AECOM Program Managers for every newly awarded contract to go over the plan approach to meet our SB goals. We review named SB subcontractors and resources available to them and strategies for goal attainment. We also hold sessions with Program Managers when SB goals are provided, we seek to identify SB firms in the various categories that will allow us to meet all goals by contract completion SB Incentive Award Monetary Award made quarterly within our procurement group to the individual that has had the biggest impact on SB goal performance SB Check List Used when not soliciting a SB. Required to be signed by the SCA, PM, and approved by the SBLO Includes contract level SB goals, our progress against those goals, and the named SB subcontractors in the proposal/subcontracting plan Recognition of AECOM Program Managers 6

7 Individual Subcontract Report (ISR) AECOM s Process Ensures Accountability of Program Managers For every ISR we submit, we work closely with each of our Program Managers to ensure that comments provide a full description of the efforts we are making on each contract. Program Managers commonly engage Project Managers to provide specifics on efforts we have made or challenges we have faced in incorporating the various types of SBs. This is common on our IDIQ contracts. For contracts where the PM is not fully engaged or progress is slow, we will add that contract to our SB Performance Review lists for the next period. The ISRs that are submitted become SB Past Performance so it vital to capture challenges, success, and other details that put the performance in context There is no limit to the amount of information that goes into the Remarks section. We typically list our firm s SB outreach activities but also encourage Program Managers to list specific outreach or SB searches they conducted in support of their contract. Some clients require a TO accounting of efforts. These require Program Mangers to keep track throughout the year of efforts on individual TOs 7

8 Questions?