19.705-6
Postaward responsibilities of the contracting officer
Contracting officers must actively monitor, document, and enforce compliance with subcontracting plans postaward, ensuring timely reporting and coordination with the SBA and contract administration offices.
Overview
FAR 19.705-6 outlines the postaward responsibilities of the contracting officer regarding contracts or modifications that include a subcontracting plan. The regulation details the steps contracting officers must take to ensure proper notification, documentation, monitoring, and enforcement of subcontracting plans, with a focus on supporting small business participation. It emphasizes coordination with the Small Business Administration (SBA), contract administration offices, and the use of the Electronic Subcontracting Reporting System (eSRS) for compliance tracking and reporting.
Key Rules
- Notification to SBA
- Contracting officers must send copies of award documents and commercial plans to the appropriate SBA offices.
- Distribution of Subcontracting Plans
- Copies of subcontracting plans and approvals must be provided to SBA procurement center representatives and contract administration offices.
- Monitoring and Reporting
- Officers must monitor contractor compliance, ensure timely submission and review of subcontracting reports in eSRS, and acknowledge or reject reports as appropriate.
- Evaluation and Enforcement
- Officers must evaluate contractor good faith efforts, assess explanations for non-use of small businesses, and initiate liquidated damages or enforcement actions when warranted.
Responsibilities
- Contracting Officers: Notify SBA, distribute plans, monitor compliance, review reports, evaluate contractor performance, and enforce contract terms.
- Contractors: Submit accurate and timely subcontracting reports, comply with approved plans, and provide explanations for deviations.
- Agencies: Oversee contracting officer actions and ensure regulatory compliance.
Practical Implications
- Ensures transparency and accountability in subcontracting to small businesses.
- Requires diligent tracking and documentation by contracting officers.
- Common pitfalls include late or incomplete reporting, failure to notify SBA, and inadequate monitoring of contractor performance.