Responsibilities of the contracting officer under the subcontracting assistance program
Contracting officers are responsible for ensuring that subcontracting plans are properly required, reviewed, approved, and enforced to maximize small business participation in federal contracts.
Overview
FAR 19.705 outlines the specific responsibilities of contracting officers in administering the Small Business Subcontracting Program. This section covers the full lifecycle of subcontracting plan requirements, from determining when a plan is needed, preparing solicitations, reviewing and approving subcontracting plans, making awards, and ensuring postaward compliance. The goal is to ensure that large prime contractors provide maximum practicable opportunities for small businesses, including small disadvantaged, women-owned, veteran-owned, and HUBZone firms, to participate in federal contracts as subcontractors. Contracting officers play a central role in enforcing these requirements and monitoring contractor performance against approved plans.
Key Rules
- Determining the Need for a Subcontracting Plan
- Contracting officers must assess whether a subcontracting plan is required based on contract value and business size.
- Preparing the Solicitation
- Solicitations must include appropriate clauses and requirements for subcontracting plans when applicable.
- Reviewing the Subcontracting Plan
- Contracting officers are responsible for reviewing, negotiating, and approving subcontracting plans submitted by offerors.
- Awards Involving Subcontracting Plans
- Awards cannot be made without an approved subcontracting plan when required.
- Postaward Responsibilities
- Contracting officers must monitor contractor compliance with the plan and take corrective action if necessary.
- Compliance with the Subcontracting Plan
- Contracting officers must ensure contractors meet their subcontracting commitments and report on performance.
Responsibilities
- Contracting Officers: Determine plan requirements, include clauses in solicitations, review and approve plans, monitor compliance, and enforce corrective actions.
- Contractors: Submit compliant subcontracting plans, execute commitments, and report on performance.
- Agencies: Oversee program effectiveness and ensure compliance with small business subcontracting goals.
Practical Implications
- This section ensures small businesses have fair opportunities in federal contracting.
- Contracting officers must be diligent in plan review and enforcement to avoid noncompliance.
- Common pitfalls include inadequate plan review, failure to monitor performance, and missing required clauses.