Reminder (from USAID) on Small Business Subcontracting Reporting

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Dear Contractors,

The purpose of this letter is to remind those prime contractors whose awards contain a small business subcontracting plan to conduct the required reporting in the Electronic Subcontracting Reporting System (eSRS), available at eSRS.gov.  Contractors must comply with the requirements in the FAR 52.219-9 (“Small Business Subcontracting Plan”) clause found in their contract, as applicable. Small businesses are an important part of the USAID partner community and, when applicable, large contractors are expected to ensure that they are meeting their subcontracting goals.

In addition to being a contractual requirement, this reporting is vital for USAID to monitor the utilization of small businesses and track progress against the Agency’s small business subcontracting goals. This reporting also supports the achievement of Objective 3.3 (“U.S. small businesses and underserved U.S. partner communities engaged more equitably”) in USAID’s recently-updated Acquisition and Assistance Strategy, as well as the President’s focus on Advancing Equity in Federal Procurement.

Resources:  Guidance and training tools are available to support prime contractors in complying with eSRS reporting. Please refer to the eSRS Contractor User Guide, the eSRS Quick Reference Guides and Webinars, and the eSRS Frequently Asked Questions (FAQs)

Data integrity:  In reviewing past subcontract reports in eSRS, USAID has identified a number of cases of missing data or other inaccuracies with the data reported by prime contractors.  In some cases, there have been discrepancies between the subcontracting goals manually entered in the eSRS subcontract report and the subcontracting goals stated in the contractor’s approved subcontracting plan.  In other cases, the prime contractor fails to include any information or narrative in the “Remarks” field to explain the reason(s) for any shortfalls in achieving the small business goals, any future plan of action to meet those goals, or any information helpful to the Government official who reviews the report.  Another issue is that – if a contract requires task/delivery order level data – all orders must be included and all mandatory fields must be completed in order to submit the report.  One final piece of information that is critical for all subcontract reports is to ensure the email address for the Contracting Officer is included in the appropriate field as one of the persons to be notified that the report has been submitted; this ensures the report is routed to the cognizant Contracting Officer for review.  

To improve the accuracy of future subcontract reports, I am requesting that prime contractors ensure proper procedures are in place to address these data integrity issues as part of any applicable eSRS reporting.

Finally, I want to take the opportunity to highlight the new Sub-Opportunities Portal on WorkwithUSAID.org, which provides an option for contractors to raise the visibility of subcontracting opportunities and to seek out new small businesses.  Please visit the portal to learn how to post subcontracting opportunities.

We appreciate your efforts to ensure that applicable small business subcontracting is accurately reported in eSRS.  If you have any questions regarding small business subcontracting reporting, please contact your cognizant Contracting Officer.

You can find a copy of this notice signed by the USAID Senior Procurement Executive on the IPN Acquisition Portal.

Mark A. Walther
Director
USAID Bureau for Management
Office of Acquisition & Assistance

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