1. Comprehensive Subcontracting Plan

    1.1. Defense Contract Management Agency (DCMA) Small Business Center Comprehensive Plan Program Managers ( CP PM) in coordination with the Comprehensive Plan Program Division Chief (CP DC) and the DCMA Small Business Center Director (CD) communicate the objectives of the Comprehensive Subcontracting Test Program during regular contractor and customer discussions.
    1.2. The CP DC should personally and actively engage with the contractor, at least annually, regarding the company's performance under the Program.
    1.3. CP PMs should obtain from the Comprehensive Subcontracting Plan Test Program participants three new initiatives to be implemented during the year to improve its Small Business Center Director business performance.  For each initiative, the participant should identify the business unit, profit center or corporate officer (as appropriate) with primary responsibility.  The participant should also outline how each initiative enhances the defense industrial base.  Further, for each initiative the participant should include performance metrics that can be tracked and reported. Participants are strongly encouraged to ensure that these initiatives target Small Business areas needing the most attention based on gaps in your current year performance. Additionally, participants should include separate, specific goals (and timetables) for the awarding of subcontracts in two industry categories which have not historically been made available to business concerns.
    1.4. CP PMs should conduct periodic reviews throughout the year to assess the participant's overall performance.  Reviews are to target areas that are deemed weaknesses during review of the Comprehensive Plans and documented in Work Plans (see paragraph 5.10. below).
    1.5. Comprehensive Subcontracting Plans should be prepared in accordance with the "Test Program for Negotiation of Comprehensive Small Business Subcontracting Plans" as published in the Federal Register/Vol.65, No. 31/ Tuesday, February 15, 2000 and in prescribed Comprehensive Subcontracting Plan format.  Comprehensive Subcontracting Plan (on a corporate-wide basis) should reflect goals down to Business Units and major purchasing sites.  The cognizant  CP PMs must receive the plan no later than August 15th.  Upon receipt the CP PMs should forward copies to the Military Service Office of Small Business Programs and Customers with an August 30th suspense for comments.
    1.6. The CP PMs receive and evaluate the proposed plan in accordance with FAR 19.705-4 and DFARS 219.705-4.
    1.7. Analysis of the subcontracting plan is performed by the CP PMs using the participant's initiatives, prior subcontracting plans, prior and current SF 295 Summary Subcontract Reports, and Surveillance Reports as described in the Instructions for Small Business Negotiation Support Memorandum (NSM).   In the General Information of the aforementioned document, the CP PMs will incorporate:

• The number of years the contractor has participated in the Comprehensive Subcontracting Plan (CSP)
• Which Divisions or parts of the corporation the CSP will cover.
• Score Card Information - Report cards to senior leaders on small business performance. Contractors will  represent their commitment to small business by report card activity.  Look for scorecard information to determine progress/trends.
• Past Performance -  Contractors are to provide performance information for previous year.
• Metrics for Initiatives are required elements of the CSP as stated in 1.3 above.
• CP PMs will prepare a Post Negotiation Memorandum to document findings on agreed to actions.

    1.8. The CP PMs prepare the Negotiation Support Memorandum (NSM) and establish the government's negotiation objectives.  If anticipated goals are less than prior fiscal year, rationale as to why the goals are lower is required. 
    1.9. The CP PMs incorporate customer comments into the NSM and/or subcontracting plan as applicable.  NSM will address all customer comments and program level reporting requests.  Rationale will be made to justify inclusion or non-inclusion of customer comments and program level reporting. 
    1.10.  The CP PMs coordinates the NSM through the Division Chief to the CD for concurrence no later than September 10th. 
    1.11. The CP PM will promptly notify the CP DC, if problems occur which will impede signature of the plan by the contractor and the CD.  Notification shall be the most expeditious means available followed with a written documented account of the circumstances.
    1.12. CP PMs complete negotiations with the Comprehensive Subcontracting Plan Participant no later than September 30th. Signature of the Comprehensive Subcontracting Plans will be executed by the CD.
    1.13. Upon negotiation and acceptance of comprehensive subcontracting plans and goals, the CP PM forwards one copy of the plan to each of the following by October 15th.  Copies of the negotiated plans are needed by the Contracting Officers (ACO, PCO, DCEs, and DACOs) by October 1.    

• Director, Office of Small Business Programs
  Office of the Deputy Under Secretary of Defense (Acquisition, Technology and Logistics)
  201 12th St. South

  S uite 406
  Arlington, VA  22202
   

  Military Department and Defense Agency Points of Contact (POC)

   

  • Department of the Army:
    Tracey Pinson
    Tracey.Pinson@hqda.army.mil
    703-697-2868

  • Department of the Navy:
    Oreta Stinson
    Oreta.Stinson@navy.mil
    202-685-6492

  • Department of the Air Force:
    John Caporal
    John.Caporal@pentagon.af.mil
    703-696-1103

  • Defense Logistics Agency:
    Peg Meehan
    Peg.Meehan@dla.mil
    703-767-1662

  • Missile Defense Agency:
    Lee Rosenberg
    Lee.Rosenberg@mda.mil
    703-553-3403

  • DCMA Small Business Center Director  (include final NSM)

  • Cognizant Administrative Contracting Officer, Defense Corporate Executive or Divisional Administrative Contracting Officer  (include final NSM)

     1.14. After the Comprehensive Subcontracting Plan is negotiated, CP PMs schedule mid-year and final performance reviews. The mid year reviews are due by June 30th.  The final reviews are completed by November 15th.  The 640 Surveillance Reviews are conducted only if the contractor's risk assessment is High or Moderate. Use of the revised DCMA 640 Form shall be used to document the review.

High Risk

    1.15.  CP DC posts Comprehensive Subcontracting Plan Participants on OSD Office Small Business Programs website.

    1.16. The Federal Register requires a final Performance Report by December 15, 200_.  CP PM prepares final comprehensive subcontracting plan report and forwards to the CP DC by November 15th.
    1.17. The CP DC  forwards final Performance Reports with comments to CD no later than November 30th.
    1.18. CD consolidates an overall Final Performance report for submission to the OSD Office of Small Business Programs by December 15th.

2. Negotiation of Fiscal Year Plan for Existing Member of the Comprehensive Program  
    2.1. CP PM assessment of the contractor's performance year to date includes data based on the mid-year performance report and latest compliance review to determine contractor's performance against the plan.  If it is determined that the contractor should be placed on notice, the CP PM  should begin notice  proceedings in accordance with paragraph 5. below.  Based on the assessment of performance, the CP PM provides the CP DC with a list of elements/Corrective Action Plan (CAP) required for the plan.  
    2.2. CP PM obtains from the Comprehensive Subcontracting Plan Test Program participants three new initiatives that it should implement during the year to improve its Small Business performance.  For each initiative, the participant should identify the business unit, profit center or corporate officer (as appropriate) with primary responsibility.  The participant should also outline how each initiative enhances the defense industrial base.  Further, for each initiative the participant should include performance metrics that can be tracked and reported in the attachment to the Standard Form 295.  Participants are strongly encouraged to ensure that these initiatives target Small Business areas needing the most attention based on gaps in your current year performance. Additionally, participants should include separate, specific goals (and timetables) for the awarding of subcontracts in two industry categories which have not historically been made available to small business concerns.  
   2.3. The CP PM requests participants to submit plans as early as practicable but no later than August 15th. 
   2.4. Upon receipt, the CP PM distributes the plan to the CP DC for review.  Copies are forwarded by the CP DC to the CD, the Military POCs and customers with an August 30th suspense for comments. 
   2.5. The CP PM prepares the Negotiation Support Memorandum (NSM)  to establish negotiation objectives.  The NSM format should include at a minimum:

• An analysis of compliance with each  the of the 11 required elements of the subcontracting plan set forth in FAR  52.219-9

• Analysis of elements contained in FAR 19-704

• An analysis of the contractor's past performance as it relates to current proposed performance

• An analysis of the contractor's management of the program

• An analysis of the target categories and initiatives

• An overall determination of reasonableness

• If anticipated goals are less than the previous year, rationale is needed

• Analysis of the DCMA Review Questions (See paragraph 5.16.)

• Analysis of Subcontract Spend data

• Initiatives derived from gap analysis of the DCMA Review Questions (See paragraph 5.16.) and Subcontract Spend data

• Major Programs covered by the Comprehensive Plans

• Negotiation Objectives - Goal Objective should include proposed goals and recommended goals to be negotiation for all small business categories

• Justification for continuation or termination as a program participant

• Exhibits used to perform analysis, i.e. SF 295 Summary Subcontract Report, copy of latest review used for performance analysis, contractors subcontracting plan, performance history, etc.

    2.6. The NSM should be forwarded through the CP DC to the CD for concurrence by September 10th.  Comments from customers should be addressed in the NSM.
    2.7.  If concurrence is not received, the CP PM should rework position and resubmit through the same review cycle as the original NSM.  The CP PM coordinates the NSM for signatures with the CP DC and CD no later than September 20th.
    2.8. CP PMs completes negotiations with the Comprehensive Plan Participant by September 30th.

    2.9. After the Comprehensive Subcontracting Plan is negotiated, CP PMs should schedule mid-year and final performance reviews. The mid year reviews should be completed by June 30th.  The final review should be completed by November 15th.  The 640 Surveillance Review should be conducted only if the contractor's risk assessment is High or Moderate in accordance with the criteria identified in paragraph 1.14. above.  Use of the revised DCMA 640 Form shall be used to document the review.

    2.10. Upon negotiation and acceptance of comprehensive subcontracting plans and goals, the CP PM should  forward one copy of the plan by October 15th in accordance with 1.13.       

    2.11. Follow process identified in paragraphs 1.15. through 1.18.
 

3. Negotiation of Fiscal Year Plan for New Entrant into Comprehensive Program

    3.1. The CP PM receives the contractor's letter of intent to enter into the Comprehensive Test Plan Program. The CP PM should advise the contractor to submit its request to join the DoD Comprehensive Subcontracting Test Program to the Military Department/Defense Agency POC with the largest projected dollars for the current FY. Concurrent copies should be forwarded to the respective CP PM and the military services points of contact.  The CD should post POC addresses to the DCMA suspense system July 1 of each fiscal year.
    3.2. The CP PM should notify the cognizant buying command recipient that the latest past performance report on the contractor should be provided for review within one week unless an alternate submittal date is negotiated. 
    3.3. The  CP PM will notify the CP DC with the results of the past performance report and the required date. 
    3.4.  CP PMs should notify the CP DC of the contractor's intent to enter into the program. The following should be provided to the CP DC:

• Copy of contractor's request 

  Their top three major DoD programs and buying activities

  Name of  the ACO/SBS/phone numbers/cognizant CMO

  Most recent year-end SF295

• Last compliance (640) review on contractor

    3.5. The CP PM forwards information to the CD, who should send an informal notification to OSD Office of Small Business Programs. 
    3.6. The CP PM forwards the past performance report to the customer.  Copy should be sent through CP DC to the CD.
    3.7. The CP PM forwards the past performance report to the customer and requests that if the customer accepts the contractor into the program, a Letter of Notification and/or Delegation to Negotiate the plan be provided to the CP DC (Letter of Delegation is not required from the Air Force).  

   3.8.  The CP PM forwards a copy of the Letter of Notification and/or Delegation to Negotiate to the CP DC and CD
   3.9. Follow process described in paragraphs 2.1. through 2.11. above. 
 

4. Process for voluntary withdrawal from Comprehensive Plan
    4.1. The CP PM coordinates the letter of contractor's intent to withdraw from the Comprehensive Subcontracting Program. Written notification provides express rationale for decision.
    4.2. The CP PM forwards the letter to the CP DC for appropriate action.
    4.3. The CP PM provides the CP DC a written assessment of the contractor's performance while under the Program.  The assessment also include performance statistics for the three years prior to acceptance into the Program.
    4.4. The CP DC prepares a report summarizing the contractor's withdrawal and forwards it through the CD for coordination.
    4.5. The CD forwards the coordinated report to the OSD Office of Small Business Programs.

    4.6. The CP PM should notify the military department/agency POC of the voluntary withdrawal by the contractor from the comprehensive plan test program.  The CP PM coordinates with the cognizant ACO to issue a modification to delete the clause at DFARS 252.219-7004 from all contracts covered by the plan.  Contracting Officers should include small business clauses when a modification to an existing contract is equal to or greater than $500K or issuance of a new contract. (IAW FAR 19.702 Statutory Requirement)

5. Assessing Contractor performance prior to negotiations  
    5.1. The following actions should occur prior to negotiating each year's plan.  For companies that have a trend in performance that does not reflect continuous improvement, the CP PM determines if the contractor should be placed on notice.
    5.2. A written assessment should be prepared by the CP PMs on the contractor's performance.  The 640 Surveillance Review report and interim performance reviews should sustain prior discussions with the contractor regarding trend performance for two years.
    5.3. The written assessment as a part of the NSM should be forwarded through the CP DC to CD prior to negotiation of the FY Comprehensive Subcontracting Plan.  
    5.4. The CP PM should begin notice proceedings by providing the contractor with a Performance Assessment Notice.  This notice should address all relevant factors leading the CP PM to conclude that the contractor is not improving performance.  
    5.5. A Corrective Action Plan (CAP) with detailed milestones should be required and incorporated into the FY Comprehensive Subcontracting Plan.  Quarterly status meetings should be conducted to monitor the contractor's progress.  
    5.6. The CP DC should formally advise the contractor via a letter of the performance criteria required for the contractor to attain satisfactory performance.   
    5.7.  The CP PM should continue with negotiation of the FY Comprehensive Subcontracting Plan.
    5.8. Quarterly status reports are required on all Comprehensive Plan Participants on notice.  Reports are prepared by the CP PMs and forwarded through the CP DC to the CD and are due Jan 31st, Apr 30th and July 31st.
    5.9. The CP PM should send a copy of the notice and performance criteria letters along with the negotiated Comprehensive Subcontracting Plan to the CP DC, CD and the Military/agency POCs. (see paragraph 1.13).   
    5.10.  The CP PMs are to prepare Work Plans at the beginning of the FY on each Comprehensive contractor to detail activity necessary to monitor activity to attain improvement in small business performance.
    5.11.  A Work Plan format, adopted to include a Four Phase approach to monitor the contractors activity, is indicated below:

• Phase I - To become familiar with the contractor and their plan to reach goals stated in the Comprehensive Subcontracting Plan.

• Phase II - Analyze subcontracting performance and spend data to determine if opportunity gaps exist for small business opportunity.

• Phase III - Negotiate an improved Comprehensive Subcontracting Plan

• Phase IV - To perform fiscal year end review.

• Each phase includes the following:

  •  Action Item - to determine what activity requires monitoring

  • Supporting Guidance Reference  - Establishes guidance and FAR clauses which requires the action.

  • Action Planned strategy  - To determine what Action Items will be discussed.

  • Action Taken activity - To determine the method of contact to discuss Action Items with Small Business Liaison Officers

  • Deliverable & Estimated Completion Date target  - To document action item activity by writing a Memo to File and a date range when it is anticipated for completion

  • Estimated Completion Date - A date of expected completion.

• General Background - Includes information that the CP PM will review and analyze to effectively engage with the contractor:

  •  CSP Review - Are the actions in the plan supportive of the proposed goals? Were the proposed changes in the NSM incorporated in the plan? Read the plan thoroughly. Gather a general sense of the contractors program. Are the actions stated in the plan clearly supportive of their goals?

  • NSM - The Negotiation Support Memorandum provides a detailed history with trends and also highlights strengths and weakness of the contractors program. Annotate what is determined as strengths and possible weaknesses of the program. Review DCMA guidance to makes sure that all important factors were addressed. (i.e. Customer comments, special reporting...)

  • Initiatives and Target Industry - Are the Industry categories and initiatives included in the plan supportable and effective to reach the goals stated in the plan? Are there any internal metrics that address Initiatives and Industry categories?

  • Program Reporting- Did the contractor agree to include program level reporting? Distribute to customers.

  • Attachments- Are the attachments to the 295 IAW with DCMA CSP Guidebook Chapter 1?

• Performance - Includes information that the CP PM will review and analyze to effectively engage with the contractor:

  • Risk Rate - Analyze FY 2005 SF 295. Measure goals against performance. Does the contractor  have internal Metrics that address goal performance? Does the contractor attain the goals in the plan? Are they making continuous improvement? If not, is rationale provided?. Risk Rate the contractor.

  • Analyze current FY SF 295 - Did the contractor provide adequate rationale for meeting or exceeding goals? Determine the effectiveness of the contractors milestones established by the contractor.  What did the contractor do to address goals that were not achieved?

• Forecast - Determine the method used to forecast dollars and percentages used in the CSP.

• Organization - How is the contractor organized? Become familiar with Organizational Structure (Organizations of this size change frequently. – Learn the changes that effect Supplier Diversity) What are the key Business Units that have a major impact on Supplier Diversity?

• Meetings - Schedule a meeting with the SBLO to begin the review to discuss the Forecast, Spend Data, DCMA 20 Plus questions and Site visits

• Questions - Use the findings contained from your analysis above to address the DCMA 20 Plus questions

• Letter - Issue a letter of concern if any of the information above merits corrective action.

• Request for Subcontract Spend data - Prepare correspondence to formally request Subcontract Spend data and desired format. Examine how each Business Unit contributes to the CSP. From the requested data, learn each business unit, and the types of purchases made from each unit. Determine whether or not opportunity gaps exist. Obtain documentation.

• Examine Mid Year Performance - Examine the CSP against semi-annual report 2006, Is contractor making progress on goals? Document any events that have caused contractor to make or not make goals.

• Customers - Solicit comments and concerns from customers while distributing the semi-annual performance review. Provide feedback to customers semi-annually with Mid Year 295 and Final Year end review.

• Request for next FY Comprehensive Subcontracting Plan - Prepare correspondence to formally request next FY Comprehensive Subcontracting Plan.

• Prepare to Negotiate the Comprehensive Subcontract Plan - Examine and analyze the Comprehensive Subcontract Plan for negotiation.

    5.12.  Work Plans are updated on a continuous basis to monitor measurable activity until a new Comprehensive Plan has been negotiated.  Actions from previously negotiated plans can carry over to another FY if the items of concern have not been resolved.

    5.13.  Work plans that include areas of weakness as a result of analysis should become an initiative in the Comprehensive Plan
    5.14.  Programs Manager provides Work Plans to CP DC for review and comments on a quarterly basis starting October 15th, Jan 15th,  April 15th and July 15th.

    5.15.  The Comprehensive CP PM will review and  provide comments to CP PMs and forward work plans to CD for review and comments 10 days after each semi-annual submission.

    5.16.  DCMA Review Questions - Questions are used to determine how a Comprehensive Contractor is conducting their Small Business Program.  Responses to the questions will assist in determining CP PM level of engagement with the contractor.  The CP PM shall keep the contractor advised of program expectations and results of analysis are available for discussion.

    5.17.  Each question will be color coded with green, yellow or red. Green indicates action is complete.  Yellow indicates action is pending and read indicates action is not closed. Color coding will also help determine which actions to consider initiatives to track in Work Plans.

    5.18.  CP PMs are to obtain responses to questions from the contractor and analyze the responses to determine if there are any gaps in their program which can be incorporated in the Comprehensive Plans as initiatives with appropriate milestones established to track through resolution.

    5.19.  CP PMs will monitor milestones and include them in their work plans.

    5.20.  CP PMs will issue a Corrective Action Plan (CAP) on milestones that have not been completed by the designated time frame for correction.

    5.21  Corrective Action Plans will be forwarded to the CP DC for comments and through the CD for comments.  Corrective Action Plans will be definitive on the actions required for the contractor to be made well. 

    5.22. Customers identified in paragraph 1.13. above will be notified when CAPS are issued and continuously advised until resolution is achieved.

    5.23.  If the Corrective actions plans are not satisfactorily resolved and are of a magnitude which will impact continued participation in the plan, actions to issue a show cause notice should be considered. 

    5.24.  CP PMs will consult with Legal to obtain legal consult on contemplated actions and provide results to CP DC for further instructions.

    5.25.  Subcontract Spend Data must be requested and received in order to properly prepare for negotiation of the Comprehensive Plan.

    5.26  CP PMs will issue a letter to request spend data for a 12 month period with a suspense date of 30 days after receipt of letter.

    5.27.  Subcontract Spend data will be requested in a excel format. Data elements made be modified to the contractor's ability to provide the information.

    5.28.  CP PMs will analyze subcontract spend data to determine gaps in small business opportunities and consider gaps for initiatives to include in the Comprehensive Plan and document in the Work plans.

6. Modifications to Existing Comprehensive Subcontracting Plans
    6.1. Modifications to existing comprehensive subcontracting plans may occur when the CP PM determines that the scope of changes are unusual, compelling, and meet designated criteria.  
    6.2. Compelling criteria for modifications may include unanticipated major contract awards, large termination, and/or change in business structure.   
    6.3. Criteria to modify the comprehensive subcontracting plan is a monetary impact (positive or negative) exceeding 25% of the originally negotiated base of total subcontracting dollars planned. 
    6.4. The CP PM receives the contractor's request to modify the existing subcontracting plan.  The request should explain rationale and anticipated impact.
    6.5. The CP PM reviews the request to determine if it meets designated criteria and provides recommendations to the CP DC.  The CP PM prepares the Letter of Decision for CP DC signature. 
    6.6. The CP DC issues Letter of Decision to contractor on request for modification to existing plan.
    6.7. If the CP DC determines the modification meets designated criteria, follow procedures stated in guidance under paragraph 2 above.
 

7. Changing from Divisional Comprehensive Subcontracting Plans to Corporate Comprehensive Subcontracting Plans   

 
    7.1.  The contractor should submit a letter to the CP DC with their request to change from a divisional comprehensive subcontracting plan to a corporate comprehensive subcontracting plan.   
    7.2.  The contractor should submit plan on corporate level in accordance with guidance under paragraph 1.5.  (Given the complexity of changing from a divisional comprehensive subcontracting plan to a corporate comprehensive subcontracting plan, the contractor's intent should be provided well in advance of the normal negotiation cycle.)  
    7.3.  Follow procedures stated in guidance under paragraph 2 above.

8.  Risk Assessment

    8.1.  Receive and review the Comprehensive Subcontracting Plans, the Semi-annual Summary Subcontract Reports (SF295) and the DoD Annual Reports. DoD semi-annual reports are to be submitted by the contractor for the following periods of performance:  October 1 through March 31 and October 1 through September 30 of each fiscal year.  The DoD Semi-annual Reports should be received by the CP PMs no later than April 30 and October 30, respectively. The CP PMs verifies the contractor's completed Semi-annual Summary Subcontract Report (SF295).  
    8.2. Each plan is negotiated and monitoring and performance schedules are established.  The CP PM requires the contractor to identify the root causes for its low performance targets and provides recommendations to the CP DC in determining the actions required to maximize contractor small business subcontracting performance. In order to provide the customer with an assessment of the risk of a contractor's successful compliance with contract requirements, the CP PM considers contractor past performance or lack of past performance, program infrastructure, demonstrated level of commitment, sourcing behavior and affected commodity groups and where they are on work plan issues, weaknesses, etc.

9.  Risk Handling

    9.1.  Comprehensive Small Business Subcontracting Plan Test Program (DFARS 219.702) plans should be coordinated with customers, CP DC and CD. CP PMs should obtain and consider the recommendations of the customers, CP DC and Small Business Center Director in developing negotiation objectives. The CP PMs analyze current contractor performance, achievements, and other pertinent data to provide recommended goals and specific objectives to the CP DC.
    9.2. After the Comprehensive Subcontracting Plan is negotiated, CP PMs should schedule mid-year and final performance reviews. The mid year reviews should be completed by June 30th.  The final review should be completed by November 15th.  The 640 Surveillance Review should be conducted only if the contractor's risk assessment is High or Moderate. Use of the revised DCMA 640 Form shall be used to document the review.
 

High Risk