Proposal Development and Submission

Small Business Subcontracting Plans

The University has a growing number of federal contracts that require small business subcontracting plans. This document is intended to provide guidance on the preparation and reporting required for such plans, and to set out the responsibilities of the various parties involved in their preparation and submission.

  • The University of Chicago is committed to providing enhanced opportunities for small business concerns to participate in the economic opportunities arising from the University's business activities (see University Financial Policy 1205, "Minority-owned, Women-owned, and Small Business Enterprises Procurement Policy"). In addition, the University has accepted a number of federal government contracts with provisions requiring small business subcontracting plans, or similar requirements for documenting affirmative steps taken to utilize minority business enterprises.

  • A small business subcontracting plan is required on federal contracts that are expected to total an estimated cost of $500,000 or above for the entire period of performance. A small business subcontracting plan is also required of any subrecipient whose total dollar subcontract amount is expected to exceed total costs of $500,000 for the entire period of performance.

  • Any non-personnel (non-salaried) supplies or services required for performance of the contract are legitimate expenses to consider for a subcontracting plan. The principal products/services subject to the purposes of a small business subcontracting plan include direct costs such as: lab supplies, lab equipment, rental items, travel, office supplies and office equipment dedicated to the project, computers, software, furniture, moving expenses, meeting accommodation and special events that may be sponsored by the contract. Any work included in your budget which will be formally subcontracted (i.e., a portion of the scope of work is contracted out to a subrecipient via a subcontract) to another entity, may also be included in the plan to use a small business.

  • Central Procurement Services (CPS) and the Director of Business Diversity will make every effort to assist in the identification of diverse suppliers for inclusion and use under the plan.

  • A sample form for a small business subcontracting plan is usually incorporated as an attachment to an RFP

  • A small business subcontracting plan is generally required to be submitted with the proposal, usually as part of the Business Proposal-it is subject to negotiation during the negotiation phase of a proposal

  • Federal agencies have established subcontracting goals and generally include them with each RFP; the goals are also often set out in the sample form for a subcontracting plan

  • At the time of the proposal, it is generally sufficient to prepare the subcontracting plan for the base year of a multi-year proposal

Responsibilities of University Parties

    URA Responsibilities
    • Review and sign final plan submitted with proposal
    • Review and sign final plan submitted with proposal
    • Maintain list of Small Business Subcontracting Working Group (SBSWG)
    • Post some advice on website for preparing and reporting on small business subcontracting plans
    • Organize meetings of SBSWG
    • Notify Nadia Quarles in Central Procurement Services when a contract, which required a small business subcontracting plan, has been awarded
    CPS Responsibilities:
    • Develop and maintain a list of University approved/recommended vendors to satisfy the small business subcontracting plan requirements
    • During proposal development, reviews a draft of small business subcontracting plan prior to URA review and signature, and provides advice to the administrator preparing the Plan as to its feasibility (given CPS knowledge of vendor possibilities)
    Administrator Responsibilities:
    • Prepare small business subcontracting plans, submit to CPS for review, submit to URA for final review and signature
    • Prepare and submit required reports, with copies of Standard Form 294 and Standard Form 295 sent to CPS-Attention: Nadia Quarles
    • Provide feedback to CPS concerning vendor performance

The Process

  1. Administrator--Prepare the proposal budget
    Generally, prices from catalogs or even recent past purchases elsewhere are all that is needed at proposal time (they are needed to support your budget estimates, not purchasing decisions at this time. Note however, in some circumstances, vendor quotations must be provided for equipment purchases). Any supplier's estimates can be used to construct the budget proposal plans without extensive detail. Include the name of the supplier (for example, if you normally buy lab supplies from a particular vendor-name them). Categories -- like lab supplies, lab equipment, rental items, travel, office supplies dedicated to the project, computers, software, furniture, moving expenses, meeting accommodation and special events that may be sponsored by the contract -- and dollar estimates for those categories are what Central Procurement Services (CPS) needs at this stage. They are looking for estimated expenses on a yearly basis.

  2. Administrator--Prepare a draft small business subcontracting plan
    Fill out the sample form for a small business subcontracting plan using the sample form included in the RFP. Try at least to meet the recommended goals indicated on the sample form or in the RFP, as your budget allows. If you have a significant amount of travel, for example, you might exceed the goal for a particular small business category (depending on the small business category into which your travel agent fits)

  3. Administrator--Submit the non-personnel portion of your budget and a draft small business subcontracting plan to CPS-Attention: Nadia Quarles
    CPS will take your $$$ estimates and what you are planning to buy (by category), and from which vendor, and they will then attempt to suggest a small business vendor (minority, woman-owned, etc) as an alternate source that you can expect to buy from in order to meet your SBA commitment (please give them sufficient time for review prior to proposal due date). A draft of your plan, with the goals you have set for the contract, will help CPS to determine whether it appears realistic in light of your budget and their knowledge of eligible suppliers. (They might, for example, be able to suggest a woman-owned small business (WOSB) as a supplier for one of your categories, and you might then increase your subcontracting goal for WOSB). If they do not have an immediate recommendation at the time of your proposal preparation, you can submit the intended dollar estimates to the agency and CPS will do some research in order to locate an appropriate vendor. Between proposal submission and issuance of award, the agency may request a revised small business plan. At that time, CPS can provide more information.

  4. After a plan has been approved and an award has been made
    A copy of the fully signed small business subcontracting plan is attached to the contract. Actual pricing happens at time of purchase, unless the supplier is already under contract with the University. Submit Purchase Request or process a POPS order as soon as funding becomes available.

    A semi-annual report during the entire period of contract performance (for periods ended March 31 and September 30) is required for each contract that contains a subcontracting plan. A separate report is also required for each contract at contract completion. Reporting is not optional and should be adhered to. Reports are submitted for each period to document the effort and utilization of diverse suppliers. These reports are prepared on Standard Form 294 and submitted according to the general directions accompanying the form. An information copy of the report should be sent to:
    Michael A. Kowalesik, Commercial Market Representative, U.S. Small Business Administration, Office of Government Contracting, 500 West Madison Street, Suite 1250, Chicago, IL 60661-2511.

    A semi-annual report during the entire period of contract performance (for the 6 months ended March 31 and the 12 months ended September 30) for contracts with the Department of Defense (DOD), and an annual report (for the 12 months ended September 30) for contracts with civilian agencies (NIH, for example) are also required. These reports are prepared on Standard Form 295 and summarize all of the subcontracting plans by unit of the University. For example, if the Department of Medicine has 2 NIH contracts, each with a small business subcontracting plan, then twice each year Medicine would fill out two Form 294s (one for each contract), and one Form 295 (which would summarize on the single report the information for the 2 contracts in the department).

    Reporting form for the Environmental Protection Agency (EPA), Form 5700-52A, may be found at http://www.epa.gov/osdbu.
squares