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Process - Process Description
 

1. Small Business Review Process

    1.1. The Defense Contract Management Agency (DCMA) Small Business Center (SBC) Director and the Assistant Directors of Small business (ADSB) of the East and West Divisions of the Center communicate the objectives of the East and West Divisions during regular and stated meetings and discussions with the primary customers of the Department of Defense.

    1.2. SBC East and West Division customers are divided into teams by the major buying agencies.  The East Division’s primary customers are Air Force, Army and all other Army Agencies.  The West division's primary customers are Navy, Marine Corps, Defense Logistics Agency and all other Department of Defense (DoD) Agencies (ODAs).

    1.3. The divisions are responsible for (1) pre award small business subcontracting plan reviews, (2) evaluation and monitoring of contractor small business subcontracting performance, (3) review and monitoring of Procurement Technical Assistance Centers (4) advising, counseling, and assisting contracting officers (PCO), CPSR and any other DCMA personnel in furtherance of the understanding and administration of prime contractors small business subcontracting programs in accordance with Federal Acquisition Regulations, Defense Acquisition Regulations,  Department of Defense Grants and Agreement Regulation and  the applicable acquisition sections of the Small Business Act.

    1.4. Each ADSB is assigned to a prime contractor based on the preponderance of the contractor’s contract dollar awards by the primary customer.  If the contractor has contracts with several buying agencies, the determination of the preponderance of work will be based upon the dollar amount of the contracts awarded and the contractor will be assigned to one major buying activity.  The assigned ADSB will be responsible for the contractor's entire subcontracting activity.

        1.4.1. The ADSB should be actively engaged with the assigned contractors and the geographically assigned PTACs at a minimum 1 time a year.

        1.4.2. The ADSB shall only conduct annual small business program reviews on those contractors that have the major impact upon DCMA’s target small business goals.  The ADSB will assess the remaining contractors based on their overall performance and annual small business summary reports.  The on site annual reviews shall be determined based upon the contractor’s overall subcontracting dollar awards at +$100M and the contractor’s performance.  Other factors for performing reviews shall be determined by the ADSB with concurrence from the Division Chief (DC).  The factors may include: past risk rating of high or medium, customer request, major personnel changes, company acquisitions, etc.

            1.4.2.1. The reviews shall focus on the contractor’s deficiencies in small business subcontracting performance, based upon completed subcontracting plan reports.  If during the year no subcontracting plan is completed and reported as final, the ADSB shall focus on plans which are near contract completion, to make a decision on the anticipated contractor’s performance.

        1.4.3. The ADSB shall conduct and participate in CPSR reviews, PCO pre-award negotiations, or post-award conferences, as requested.   Reviews of Procurement Technical Assistance Centers (PTAC) will be performed as delegated by the Defense Logistics Agency Grants Officer or Administrative Grants Officer (AGO).  The reviews will be in accordance with the DCMA Grants Guidebook.  The reviews can be virtual or physical reviews and will be in concurrence with and approved by the Division Chief.

    1.5. The contractor’s small business subcontracting performance shall be input in the DoD data management system, SIAD (formerly DIOR), by the ADSB on a bi-annual and annual basis for contractors which have only DoD contracts and annually for contractors that provide commercial products to the DoD.  The reporting period is October 1- March 31 and April 1- September 30 for the bi-annual reports and October 1- September 30 for the annual reports.

    1.6. Small Business Program Reviews shall be made in accordance with the  640 review guide.  The ADSB shall submit the request for review 30 working days before the review is performed.  In accordance with the DCMA and SBA memorandum of understanding DCMA/SBA MOU, the SBA shall be notified of anticipated plan reviews.  The small business program reviews will be performed in accordance with the MOU. 

    1.7. When a prime contractor has active contracts containing subcontracting plans with both DoD and civilian agencies, the DCMA and SBA field personnel should do a joint review whenever possible.

        1.7.1. DCMA and SBA may use their own forms and procedures for the joint review.   However both agencies must use the Analysis of Government Contracts Form or the SBA’s most current review form.

        1.7.2. Since the SBA’s rating is representative of all contracts, including the DoD contracts, the SBA must determine the contractor’s overall program rating on every joint DCMA/SBA compliance review. SBA will be the lead agency on all joint compliance reviews.         

            1.7.2.1. In cases where DCMA and SBA do not reach agreement on findings and/or overall rating, either reviewer may request a ruling from DCMA and SBA headquarters.  In such instances, the ADSB  should prepare a memorandum to the DC summarizing their objections.  The DC will then discuss the objections with the appropriate SBA personnel to resolve the dispute.  If an agreement can still not be reached, the DC will elevate the issue to the DCMA Headquarters Small Business Office.

        1.7.3. DCMA and SBA shall prepare one letter to the contractor summarizing the results of the review.  The letter should clearly state contractor performance on DoD contracts as well as overall contracts.

        1.7.4. For DCMA reporting purposes, the DCMA ADSB shall prepare the Form 640 in accordance with the review guide and enter the report into the Small Business Management System.  A copy of the joint letter, which was submitted to the contractor, shall be maintained in the ADSB files on the contractor that has been reviewed.

     1.8. The ADSB is to conduct all types of small business subcontracting plan reviews in accordance with FAR 19.702.   

        1.8.1. Master small business subcontracting plans are reviewed and signed by the SBC DC, who is a warranted contracting officer.  The master plan will be forwarded to the CMO ACO for their files.  All reviews for master small business subcontracting plans shall be completed in 14 working days unless another date is agreed upon by the ACO.   

        1.8.2. Commercial small business subcontracting plans are reviewed in accordance with FAR Parts 12 and 19.7 and recommendations are submitted to the requesting PCO for approval and signature.  Commercial subcontracting plans shall be completed in 14 working days unless another date is agreed upon by the requesting PCO.

    1.9. All actions shall be logged on to small business subcontracting logs.  The logs shall be forwarded to the Division Process Improvement Designee for the Center on a monthly basis for input into Metrics Manager.  Each ADSB is responsible for maintaining their subcontracting log(s)

    1.10. Upon review of final individual small business subcontracting plans, SF 294, the ADSB shall complete the final small business subcontracting report .  The review shall have comments on the contractor’s achieved goals versus the proposed goals and whether they were realistic or not.  Participation plans shall be recommended for future requirements in all SB 640a forms and small business subcontracting plan reviews. The form shall be forwarded to the DC for review.   The approved package shall be forwarded to the contracting officers (CMO ACO, PCO, CACO and DACO) and OSBP Directors by the Division Chief along with the annual report to the customer, which will be February 6 of the second quarter of the new fiscal year for the previous fiscal year end.  100% reporting on all small business subcontracting plan final performance reviews shall be made in accordance with FAR Parts 19 and 42.3.

    1.11. The SF 294  log  shall be  updated at the end of the fiscal year with the listing of all reported final SF 294s.

        1.11.1. The  SF 294 mid year log and SF 294 final year log shall be updated twice a year, 30 days after the close of SIAD report close or eSRS final report close.  The periods of performance are March 31 and September 30.

        1.11.2. The SF 295 mid year log  and SF 295 year end log shall be updated twice a year 30 days after the close of SIAD report close or eSRS final report close.  The periods of performance are March 31 and September 30.

2. Small Business Subcontracting Plan Reviews

    2.1. The ADSB shall perform small business subcontracting plan reviews (SP) throughout the fiscal year as they are received by the Small Business Center (SBC).

    2.2. The Division PT or designee will check the SBC website on a daily basis for any SP requests.

        2.2.1. The PT will forward the SP to the assigned ADSB as of the most current Division Log.

  • If the contractor is not listed on the division log the PT forwards the plan to the DC  (East and West) for assignment.

  • After the DC has assigned the contractor to an ADSB, the division log plan shall be updated by the PIO or designee.

  • The ADSB shall always update their individual log with new assignments at least monthly.

        2.2.2. For SPs forwarded directly to an ADSB by the PCO or other source:

  • If ADSB is the point of contact (POC) for the contractor, the ADSB shall log the SP into their individual subcontracting plan log  immediately upon receipt and review in accordance with FAR and DFARS

  • If the ADSB is not the POC, the ADSB shall forwarded the plan directly to the ADSB assigned in the most current SIAD\DIOR listing or  East division assignment or  West division assignment log.  The ADSB shall note on their individual log comments sections that the SP was forwarded and the date it was forwarded to the assigned ADSB.

  • If the contractor is not listed on the current division log, the ADSB shall forward the plan to the DC for assignment.  The ADSB shall note on their individual log comments section that the SP was forwarded to the DC and the date it was forwarded

  • The DC shall use the subcontracting log to annotate the assigned contractor and forward the plan.

        2.2.3. Upon receipt of the SP the ADSB shall complete the SP template located in the Small Business Management System in eTOOLS.  The ADSB shall complete the form as directed by FAR regulations and in accordance with the most current DCMA small Business policy for small business subcontracting reviews.  The DC shall on a regular basis review the subcontracting plans performed as noted on the most current subcontracting spreadsheet.  Each plan reviewed shall be for clarity and accuracy and compliance to small business subcontracting policy.

        2.2.4. The ADSB shall keep a copy of the small business subcontracting review request in their individual files in accordance with records management

        2.2.5. The method of transmission of the SP review is at the discretion of the ADSB and the requestor.

        2.2.6. The SP reviews shall be completed in seven (7) working days after receipt of the plan, unless additional time is given by the requesting official of the small business subcontracting plan. 

        2.2.7. The SP review shall be input into the SBMS eTOOLS and on the individual subcontracting plan log.

    2.3. Commercial subcontracting plans are reviewed in accordance with FAR Parts 12 and 19 and DFARS Parts 212 and 219.7.  The DCMA SBC is not required to do a formal review of a commercial subcontracting plan; it is the PCO’s option to request a review.   If a request is made by the PCO the ADSB shall:

  • Analyze it’s compliance with each of the 11 required elements of the subcontracting plan set fort in FAR clause 52.219-9 

  • Analyze its compliance with DFARS 219.704 and

  • Provide a statement as to the contractor’s past performance and provide a statement if proposed subcontracting goals are challenging and realistic.

        2.3.1. The ADSB shall complete the SP template in SBMS eTOOLS and forward to the requesting official.  The ADSB shall request a copy of the commercial plan after it has been approved and signed by the PCO.

        2.3.2. The commercial plan review shall be distributed to the PCO and a copy of the plan review shall be kept in the ADSB files.

        2.3.3. The method of transmission of the commercial plan review is at the discretion of the ADSB and the PCO.

        2.3.4. The commercial plan review shall be completed in seven (7) working days after receipt of the plan.  The commercial plan must be reviewed and forwarded back to the PCO before the end of the last approved commercial plan expires, unless the PCO has granted an extension.

        2.3.5. The commercial plan review shall be input into the Small Business Management System and on the subcontracting plan log. A copy of the commercial plan subcontracting review request shall be kept in the ADSB individual files in accordance with records management.

    2.4. Master small business subcontracting plans shall be reviewed in accordance with FAR Part 19 and 19.7 and DFARS 219 and 219.7 and clause 52.219-9.   The master small business subcontracting plan does not contain goals; the goals are submitted on individual subcontracting plans with each contract award or modification.

        2.4.1. After the review of the master plan, the ADSB shall forward the subcontracting plan review with comments/recommendations to the DC for review and approval.  The DC is a warranted administrative contracting officer in accordance with FAR Part 42.   The DC has complete authority over small business issues only.

        2.4.2. After the DC has signed the master subcontracting plan, the ADSB shall distribute the plan to the contractor and the Contract Management Office ACO.

        2.4.3. The master plan review shall be input into the Small Business Management System.  The ADSB shall note this is a Master Subcontracting Plan in the comments section of the SBMS and on the individual subcontracting plan log. A copy of the master subcontracting plan shall be kept in the ADSB individual files in accordance with records management.

        2.4.4. By October 31 of each year, Division logs (East and West) shall be consolidated into one log by the Division PIO or designee.  The consolidated log shall be placed into the metrics manager

3. Participation Plan

    3.1. A participation plan and a small business subcontracting plan are two different types of plans that can be used during evaluation of a small business subcontracting proposed plan.  The small business subcontracting plan is a statutory requirement in accordance with FAR Part 19.7 and the participation plan is not.  Each is designed to meet different requirements.  In the participation plan, the contractor may count first, second, and third tier subcontracts in the satisfaction of the DoD target goals.  The small business subcontracting plan does not allow counting of lower tier subcontracts.

    3.2. A small business contractor isn’t required to submit a small business subcontracting plan in accordance with FAR Part 19.702.  A small business subcontractor may be subjected to the requirement of a participation plan in accordance with FAR Part 19.1202.

        3.2.1. The purpose of a participation plan is to ensure that a designated percentage of a contract is awarded to the different subcategories of small business.

        3.2.2. The ADSB shall include in all small business subcontracting plan reviews, submitted without a participation plan, a statement recommending the use of a participation plan: 

STATEMENT:  Market research is not available at this time to determine the appropriate goals for this solicitation.  However, for the goals that are to be negotiated for this subcontracting plan, it is recommended that the PCO include the participation clause. 

4. Division Workload Assignment/Yearly review

    4.1. During the fiscal year contractors are receiving awards that have small business subcontracting requirements of  +$550 thousand  FAR Part 19. The SBC receives notice of new awards and contract modifications in several ways: from the CMO ACO, the primary customer, or directly from the contractor. 

    4.2. The Division Procurement Technical Assistant (PT) or designee shall access the DCMA contractor web databases (MOCAS/EDA/EDI) for Contract Receipt and Review on a weekly basis to look for new contract or modification awards that meet the small business subcontracting plan requirements.

        4.2.1. The PT or designee will forward the new contract notices to the assigned ADSB. The assigned contract shall be recorded on the division log for the individual ADSB.  

        4.2.2. The ADSB shall log the new contract/modification on the individual subcontracting plan log

        4.2.3. This is the official way new contracts will be assigned.  The assignment of new contractors will be assigned by the Division Chief (DC).  After the DC assigns a new contractor, the PIO or designee will forward the information to the ADSB.  The new contractor will be added to the Division log by the PIO.  The ADSB will add the new award and/or contractor to their individual subcontracting log.

    4.3. If the contract award does not have a small business plan attached, the ADSB shall submit a Contract Deficiency Report DD 1716, Small Business Management System, to the CMO ACO and the PCO for action.

    4.4. On a yearly basis at the end of the DoD fiscal year, September 30, the ADSB will begin receiving Summary Subcontracting Reports (SF 295)  from all of their assigned contractors.  The reports may be received manually or input into the eSRS system where the ADSB shall retrieve and review the report.  The subcontracting summary data shall be entered into the SIAD data base manually if reports are received manually.  Information entered into the system is used for Congressional reporting by the DoD OSBP.  After the SF 295 data has been input into the system, the information is retrieved by the metrics manager assistant or PIO assigned by the Division Chief.  The data submitted is the contractor’s small business subcontracting summary report for the fiscal year.  The report is a contractual requirement and is a part of each individual SP in accordance with FAR.
DoD Implementation of the Electronic Subcontracting Reporting System (eSRS) and Reporting Functions (INFORMATION)

    4.5. The DC receives a complete listing of the data that is input and reviews for accuracy.  This listing is submitted 30 working days after SIAD closes.  The list is used to determine the top influence contractors based upon subcontracting dollars of  +$100M reported by the contractors.  These top influence contractors  are assigned in accordance with the division’s primary customers to ADSB’s. Only the DC has the authority to assign or change workload to individual ADSB’s.  All changes/corrections/deletions will be added to the West or East Division SIAD.   The DC shall provide the updated list of all contractors assigned and the influence +$100M contractors 45 days after SIAD closes.  After the data input has been validated by WHS via SIAD or eSRS, the Influence Contractor Listing will be reviewed by the DC to determine if the proper contractors have been designated as Influence Contractors.

    4.6. The Division PIO will update the Division log (East and West) with the new assignments, if any, and will maintain the log for the Division.  The  SIAD list  will be maintained by the SBC procurement analyst.  The Master SIAD log shall be posted bi-annually (30 days after close of SIAD or eSRS for mid fiscal year/ 45 days after close of SIAD or eSRS for end fiscal year).

    4.7. The division PIO shall update the subcontracting log.  The ADSB shall provide their individual work logs on the 1st Monday of every month to the PIO for the previous month work.  The PIO will forward the Division log to the DC the 2nd Monday of the month.  The Individual logs will be posted on Metrics Manager monthly by the Metrics Manager administrator.

5. Small Business Program Review (640)

    5.1. The ADSB shall perform an annual program review of all Influence Contractors on the "Plus 100" log.  Influence Contractors represent the top contractors that influence the SBC small business target goals.   This log shall be maintained by the PIO and shall be located on the small business shared drive for all SBC Center personnel to access.  Any other program reviews by the ADSB will be assigned by the Division Chief (DC).

    5.2. Prior to the review, the ADSB shall assess the past small business program review and the contractor’s assigned rating for the past fiscal year.  The rating assigned is in accordance with the DCMA and SBA Memorandum of Understanding  DCMA/SBA MOU program review rating criteria and is located on the subcontracting log.  The program review covers at a minimum the Government fiscal year or the contractor’s previous year.  The review period does not necessarily have to begin where the previous review period ended. 

    5.3. The ADSB shall inform the contractor of upcoming reviews at a minimum of 30 working days before the planned review.  The notification letter to the contractor is to include a copy of the Form 640.  The contractor shall be requested to complete the form and return to the ADSB.  The notification shall also be sent to the Small Business Administration in accordance with the MOU.  All logs shall be updated with planned review dates.

        5.3.1. In the notification letter to the contractor the ADSB shall request specific information that can be mailed prior to actual review.  Specific information to be considered for request shall include, but not be limited to:

  • 640 form

  • Listing of all contracts with a copy of the small business subcontracting plan

  • Organization chart

  • Listing of al contractual internal documents that show small business policy and

  • List of outreach activities for the review period

        5.3.2. The ADSB shall also review all SF 294 Individual Subcontract Reports submitted during the review time period, along with the current SF 295 Subcontracting Summary Report.

    5.4. The ADSB is responsible for reviewing and evaluating a prime contractor’s small business program. 

        5.4.1. This includes but is not limited to:

  • Determining whether the contractor has a valid subcontracting plan in all applicable contracts

  • Determining whether the contractor’s subcontracting practices effectively enable small businesses to receive fair and equitable subcontracting consideration and

  • Determining whether subcontracting practices promote the best efforts to achieve subcontracting goals and comply with all applicable procurement policy and regulations.

        5.4.2. The ADSB has the primary responsibility of developing a working knowledge and understanding of the accounting practices utilized by the contractor being reviewed.

        5.4.3. The ADSB is responsible for the accurate completion of the contractor’s subcontracting program review.

    5.5. On the day of the contractors program review, the ADSB shall provide an introductory briefing to the SBLO and senior management of the company to discuss the small business program review process to be performed.

    5.6. The review shall be performed in accordance with the Small Business Program Review Guide .  The time frame for a program review is determined by the ADSB.

        5.6.1. After the review is performed, the ADSB will write the review in accordance with the 640 program guide.  The review will be written on site using the Small Business Management System located at eTOOLS, if possible.  The draft 640 review form will be printed and issued to the SBLO.  The draft rating will also be given and the rating will follow the definitions assigned in the DCMA/SBA MOU.  The ratings are:

  • Outstanding - Exceeded all negotiated goals or exceeded at least one goal and met all others.  Has exceptional success with initiatives to assist, promote and utilize small business (SB), small disadvantaged business (SDB), women-owned small business (WOSB), HUBZone small business, veteran-owned small business (VOSB), and service-disabled VOSB (SD/VOSB).  However, if the contractor negotiated goals higher than the mandated DoD goals and did not achieve the negotiated goals, but still exceeded the DoD goals, an Outstanding or Highly Successful Rating may be considered.  An outstanding rating signifies that the company has an exemplary program that could be used as a model by other contractors in similar industries. 

    Highly Successful - Met all of its negotiated goals in the traditional socio-economic categories (SB, SDB, and WOSB) and met at least one of the newer socio-economic goals (HUBZone small business, VOSB, and SD/VOSB) for each contract that has two or more of these goals.  Has significant success with initiatives to assist, promote, and utilize SB, SDB, WOSB, HUBZone small business, VOSB, and SD/VOSB.  Makes an effort to go above and beyond the required elements of the program and can provide documentation and success stories to support such efforts.      

    Acceptable - Demonstrated a good-faith effort to meet all of its goals, but has not met the rigorous criteria for a Highly Successful or Outstanding rating.  Fulfills the requirements of its subcontracting plan and the regulations.  SF 294 and SF 295 reports are complete, accurate, and timely.   

    Marginal - Deficient in meeting key subcontracting plan elements, the SF294 and/or SF295 reports are not correct, or the contractor has failed to satisfy one or more requirements of a corrective action plan currently in place.  However, contractor's management does show an interest in bringing its program to an acceptable level and has demonstrated a commitment to apply the necessary resources to do so.  A corrective action plan is required, and the Administrative Contracting Officer(s) notified.   

    Unsatisfactory - Noncompliant with the contractual requirements of DFARS and FAR 52.219-8 and 52.219-9.  Contractor's management shows little interest in bringing its program to an acceptable level or is generally uncooperative. A corrective action plan is required, and the Administrative Contracting Officer(s) notified. 

        5.6.2. For rating purposes, the ADSB should include all contracts completed during the past 12 months.  For companies with a commercial plan include the results of the most recent fiscal year ended September 30th (or other period ending date, if authorized).  If a contractor with individual plans has no contracts that were completed during the past 12 months, the rating should be determined by contracts that are active, giving greater weight to those that are nearest to completion. 

        5.6.3. The ADSB shall conduct the exit briefing with the CEO or senior management, the SBLO and others who the CEO determines is a stake holder in the program.  The ADSB shall discuss each line item on the review.  The ADSB shall also discuss each item that had findings and provide recommendations and/or corrective actions as a result of the review.  The ADSB shall also note any successes or noteworthy processes, which the contractor has used to enhance its program.

        5.6.4. The ADSB shall give the SBLO and CEO a copy of the written report, which will be marked as draft.  The ADSB shall also give a date of the expected official report signed by the DC to be received by the contractor CEO or senior management.  The date shall be no more than 30 working days after the review.

        5.6.5. The review shall be completed and entered into the Small Business Management System.  The input shall be in accordance wit the 640 guide.  The ADSB must obtain approval from the Division chief before finalizing the 640 report in etools. 

        5.6.6. After the approval of the DC, the report shall be submitted to the contractor's CEO or designee and the SBLO.  A copy of the report shall also be given to the CMO ACO for their records.

        5.6.7. The completed 640 reports shall also be forwarded to the Division Metrics Manager assistant/PIO that will input each report into Metrics Manager under the reports tab or on the small business shared drive.

    5.7. The ADSB shall update the individual subcontracting log with the new rating with comments.  Corrective actions shall be monitored monthly CAR log until all corrective actions are complete.

        5.7.1. The individual  subcontracting log and CAR log  will be submitted to the Division PT for update on the 1st Friday of the month and it will be logged  into the division log the 2nd Friday of the month.  The updated logs will be loaded into Metrics Manager the following week by the assigned Metrics Manager assistant/PT.

        5.7.2. By January 6 of the second quarter of the new fiscal year, the consolidated Division log will be divided into logs for the primary customers by the PIO.  The log along with each 640 report shall be submitted to the Office of Small Business programs of the Army, Air force, Navy and other primary small business offices.

        5.7.3. The Division chiefs will submit the report February 6.

6. Notification on Prime Contractor’s Small Business Subcontracting or Program Performance

    6.1. The ADSB is responsible for assisting in evaluating subcontracting plans and for monitoring, evaluating, and documenting contractor performance. The ADSB shall provide the necessary information to the PCO by furnishing:

  • Documentation on the contractor’s performance and compliance with subcontracting plans under previous contracts;

  • Immediate notice if, during performance, the contractor is failing to meet its commitments under the clause prescribed in 19.708(b) or the subcontracting plan;

  • Immediate notice and rationale if, during performance, the contractor is failing to comply in good faith with the subcontracting plan; and

  • Immediate notice that performance under a contract is complete, that the goals were or were not met, and, if not met, whether there is any indication of a lack of a good faith effort to comply with the subcontracting plan.

    6.2. The ADSB shall provide notice of lack of performance, failing to act in good faith, potential notification of any negative impact the contractors actions might have on their subcontracting obligations.

    6.3. The report will be submitted to the DC for review and approval and after the report is approved and signed by the DC.  The ADSB shall distribute the notice to:

  • The CMO ACO for possible liquidated damages actions FAR 19.705.7.

  • The SBC Director,

  • The primary customer small business office and

  • The Small Business Administration

    6.4. All background documentations used to provide the rationale and justification of the notice shall be kept in accordance with records management

7. Contractor Purchasing System Review (CPSR)

    7.1. The CPSR reviews are performed periodically during the fiscal year on select contractors over which DCMA has administration authority.  A part of the review consists of the contractor's small business performance.

    7.2. When the CPSR team determines what contractors they will review in the fiscal year, they submit their request for small business information directly to the Division Chief (DC).  The DC will immediately assign the request to the ADSB assigned to the contractor on the request.  The DC will get the current listing of ADSBs from the SIAD  log.  If the contractor is not assigned to an ADSB and not on the SIAD log, the DC shall assign the contractor to an ADSB, based on the preponderance of work of the contractor.

    7.3. The DC shall have the division PIO log the new contractor on the West or East assignment log.

    7.4. When the ADSB receives the CPSR request, they shall immediately log the request on their individual log.

    7.5. The ADSB shall:

  • Research  www.ccr.gov to determine size and any other information on the contractor that will be of use for the review

  • Provide the past small business data as requested by the CPSR team

  • Provide a narrative on the contractor's overall performance in all small business categories, and

  • Provide any other support documents as required by the CPSR team

    7.6. The ADSB shall provide the information requested by the CPSR team by the 15th working day after receipt of the CPSR request or no later than the suspense date given by the CPSR team as a deadline.

    7.7. If the CPSR team requests the ADSB to participate in the actual review, the ADSB shall inform the DC of the request.  If the contractor is on the "Plus 100" log and a small business program review has been scheduled for the contractor, the ADSB shall make every effort to go on the CPSR review.

    7.8. The ADSB shall complete all information on the CPSR review on the subcontracting log and the subcontracting log will be submitted to the division PIO to upload into Metrics Manager.

    7.9. All documents shall be kept in accordance with records management.

8. Procurement Technical Assistance Center (PTAC) Reviews

    8.1. The ADSB is responsible for reviewing the PTAC agreements on an annual basis.  The PTAC is responsible for assisting small businesses that are interested in becoming DoD contractors.  They are the first resources that the ADSB recommends to a small business that needs assistance in DoD procurements. The PTAC is not a federal agency with government employees; they are usually not-for-profit, university, college, or state government offices.

        8.1.1. The PTAC agreement (SCAA) is administered by the Administrative Grants Officer (AGO) at the CMO in the geographic area in which the PTAC resides. 

        8.1.2. The AGO delegates to the DCMA ADSB certain responsibilities for the PTAC.  All reviews shall be coordinated with the cognizant Administrative Grants Officer.   A copy of the delegation shall be kept in the ADSB individual file in accordance with records management

        8.1.3. The delegation is for the following areas:

  • Maintain a working file for cooperative agreements.

  • Prepare recommendations for findings of fact and issue decisions on matters which the AGO has the authority to take definitive action

  • Advise the AGO when the recipient's financial condition may jeopardize the performance of the cooperative agreement

  • Assist the AGO in ensuring timely submission of a DLA Form 1806, "Procurement Technical Assistance Cooperative Agreement Performance Report"

  • Provide the AGO an assessment of the recipient's goal accomplishments at the end of the cooperative agreement performance period.

  • In coordination with the AGO, periodically review the recipient's performance under the cooperative agreement.  Reports of these reviews shall be submitted to the AGO along with recommendations for resolving any outstanding issues.  The review should include but not be limited to: compliance with certifications, representations, and other performance.

    8.2. After completion of the review, the ADSB shall submit the report within 30 working days of the review, in accordance with Department of Defense Grants and Agreement Regulation DoDGAR.

    8.3. All PTAC reviews are logged onto the individual subcontracting log and all reviews will be kept in accordance with records management.

9. Risk Handling

    9.1. After the small business program reviews have been determined by the information gathered on the SIAD/DIOR, from the Statistical Information Analysis Division (SIAD - formerly DIOR), the ADSB shall coordinate with the DC and primary customer on determining what contractors need coverage on their programs based upon subcontracting data and last program review rating.

    9.2. All contractors on the "Plus 100" and DODAAC  listing will be reviewed yearly, unless the DC and the Customer DoD Small Business Offices determines a yearly review isn’t necessary.

    9.3. The ADSB shall analyze the contractor’s performance (SF 294) achievements.  The ADSB shall maintain a log of all contractors’ submitted SF 294s.  The log shall be updated twice a year, 15 days after SIAD closes or eSRS reporting is completed. 

        9.3.1. Final SF 294’s shall be assessed as to the risk of the contractor’s small business subcontracting performance.  Final reports and data shall be included on SF 294 logs as final.  The contractor’s risk rating shall be determined based on the final reports 15 working days after receipt of the final report. 

        9.3.2. Other contractors shall be assigned risk rating based upon the annual SF 294 and SF 295 submissions.  After the rating has been given to the contractor, the ADSB shall immediately update the individual subcontracting log.  Upon the concurrence of the Division Chief , the high risk contractors shall be reviewed.  The review will be a virtual review and the ADSB shall follow the 640 review guide.

        9.3.3. The risk guidelines for goal accomplishment are as follows (negotiated goals refers to the percentage goals in the approved subcontracting plan):

  • High Risk – not meeting negotiated goals and/or DoD goals

  • Medium risk – is meeting negotiated goals but not DoD goals

  • Low risk – is meeting contract negotiated goals

    9.4. The ADSB shall record and maintain documentation on risk assessment, risk handling, and risk monitoring results and update as applicable but not less frequently than once every fiscal year. The document shall be the 640 small business program review with improvements or corrective actions on Influence Contractors or SF 294 final small business subcontracting reports.  The risk assessments must be completed by November 1 of each year.

    9.5. All contractor ratings shall be recorded in the individual subcontracting log.  All of the contractor’s SF 294 logs for the fiscal year end shall be marked for risk.

    9.6. A separate final SF 294 log will be distributed with SB  640a form evaluation to all primary customers by January 6 of the new fiscal year.

    9.7. All records shall be maintained in accordance with records management.

10. Risk Monitoring

    10.1. The ADSB can track the progress of the contractor’s small business subcontracting progress by conducting reviews of the accuracies of the SF 295 Annual Subcontracting Summary Report and the SF 294 Individual small Business Subcontracting report.

    10.2. Yearly small business program reviews of the Influence contractors (+$100M) can indicate how well the contractor is performing in all the small business categories (Small Business, Small Disadvantaged, Women, Services Disabled Veteran, Veteran, HUBZone and HBCU/MI).

    10.3. At the end of the small business program reviews, the ADSB can issue corrective actions (CAR)   and recommendations that will help the contractor increase their small business achievements.  The reviews will be in accordance with the 640 review guide.

        10.3.1. If a CAR is issued to the contractor during the program review, a mutually agreed upon timeframe for correction is determined by the SBLO, contractor senior management, and the DCMA ADSB.

        10.3.2. If all CARs are completed within the agreed timeframe and it is satisfactory to the ADSB, the ADSB shall re-evaluate the contractor’s performance rating given during the program review.

11. Risk Documentation

    11.1. The ADSB shall keep all documentation that results in changes to risk rating assignments.

    11.2. The documents shall be placed in files along with a copy of the 640 review for record.  The 640 review form, submitted in the Small Business Management System, can not be changed/corrected after it has been approved by the DC.  If the 640 must be corrected, it will be kept in the original file with back up documents supporting the change.

    11.3. All small business subcontracting plan review requests are to be kept in individual files and records of plans and actions taken shall be recorded on the individual subcontracting plan log. 

    11.4. Records of small business subcontracting reviews and small business program reviews (640) will also be recorded in the Small Business Management Systems in eTOOLS.

    11.5. All files shall be maintained in accordance with Contract  records management.

 

 

 

 
 
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cm:mary.seabolt@dcma.mil